{
    "fund_name": "Xtrackers MSCI USA Swap UCITS ETF",
    "isin": "LU0274210672",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve exposure to the MSCI USA index, which introduces counterparty risk and complexity beyond physical replication. While the fund does not use leverage or inverse strategies, the reliance on derivatives and swap counterparties makes it complex under MiFID II. The KIID explicitly mentions counterparty risk and derivative-related risks, which are key complexity indicators. The risk profile is rated at level 6, indicating higher risk, and the fund's performance depends on the performance of derivatives rather than direct investment in underlying securities. The factsheet confirms 'Indirect Replication (Swap)' as the portfolio methodology, reinforcing the synthetic structure.",
    "confidence": 90
}