{
    "fund_name": "Global X E-commerce UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using unfunded swaps",
        "Derivative counterparty risk",
        "Potential tracking error"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded total return swaps for replication, which introduces counterparty risk and potential tracking error. While the underlying index (e-commerce companies) is relatively straightforward, the synthetic replication method and derivative exposure make this a complex product under MiFID II. The KIID mentions 'derivative counterparty risk' and 'tracking error' as key risks, which are hallmarks of complexity. The PRIIPs KID would likely contain a comprehension warning, further supporting this classification. The monthly factsheet (if available) would confirm swap usage details.",
    "risk_level": "7",
    "confidence": 90,
    "counter_argument": "One might argue that since the underlying index is simple (e-commerce companies) and there's no leverage, the product should be non-complex. However, the use of unfunded swaps and derivative counterparty risk override this, as MiFID II specifically flags synthetic replication as a complexity factor regardless of the underlying asset simplicity."
}