{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using unfunded swaps",
        "Counterparty risk exposure",
        "Complex index tracking via derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication with unfunded swaps, which introduces counterparty risk and complexity beyond simple physical replication. The KIID explicitly states the use of swaps to exchange performance of held securities for the index performance, which is a hallmark of synthetic ETFs. The risk section highlights counterparty risk and the reliance on swap agreements for index tracking, which are key complexity indicators under MiFID II. The PRIIPs KID confirms the synthetic replication method and swap usage, reinforcing the complexity classification. The fund's risk category 7 (highest) also suggests a more complex risk profile. While the underlying index (KBW NASDAQ Financial Technology Index) appears straightforward, the synthetic replication method and swap exposure are sufficient to classify this as a complex product under MiFID II.",
    "confidence": 90
}