{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex ESG index methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the MSCI EM Latin America Low Carbon SRI Selection Capped Index, which involves counterparty risk. The index itself has complex ESG screening criteria (Lowest Carbon Exposure Selection Rules and Highest ESG Performance Selection Rules) that may not be easily understood by retail investors. While the ETF is UCITS-compliant and has a straightforward equity exposure, the use of swaps and the complexity of the underlying index's methodology trigger the 'complex' classification under MiFID II. The KIID and factsheet confirm the use of derivatives (specifically swaps) and highlight counterparty risk, which are key complexity indicators. The PRIIPs KID may contain additional warnings about comprehension difficulty, further supporting the 'complex' assessment.",
    "confidence": 85
}