{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Indirect replication (swap-based)",
        "Potential tracking error due to derivative usage"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve exposure to the MSCI Emerging Markets Index, which introduces counterparty risk and potential tracking error. While the fund does not use leverage or inverse strategies, the swap-based structure and derivative exposure make it complex under MiFID II. The KIID and PRIIPs documents highlight counterparty risk and the use of derivatives, which are key complexity indicators. The fund's risk profile (category 6) and the mention of 'indirect replication (swap)' in the factsheet further support this classification. The absence of leverage or inverse strategies does not negate the complexity introduced by the swap-based structure.",
    "confidence": 90
}