{
    "fund_name": "Global X Cloud Computing UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded OTC swaps",
        "Exchange-traded equity futures",
        "Potential for significant tracking error"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded OTC swaps and exchange-traded equity futures for investment purposes, which introduces counterparty risk and potential tracking error. While the primary replication method appears to be physical, the use of derivatives for investment purposes (not just efficient portfolio management) triggers MiFID II complexity classification. The risk profile is high (category 7), and the fund may invest in illiquid securities, further complicating the structure. The PRIIPs KID may contain additional complexity warnings, but the KIID alone provides sufficient evidence for classification as complex.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant and primarily uses physical replication, which could argue for non-complex classification. However, the explicit use of derivatives for investment purposes (not just hedging) and the high-risk profile override this argument.",
    "risk_level": "High (Category 7)"
}