{
    "fund_name": "Xtrackers MSCI AC Asia ex Japan ESG Swap UCITS ETF",
    "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 index methodology (ESG screening, carbon exposure rules)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve its investment objective, which introduces counterparty risk. While the underlying index (MSCI AC Asia ex Japan Low Carbon SRI Selection Capped Index) is not inherently complex, the use of swaps for replication and the ESG/carbon screening methodology add layers of complexity. The KIID explicitly mentions 'counterparty risk' as a key risk factor, which is a MiFID II complexity indicator. The PRIIPs KID and factsheet confirm the swap-based structure. While the ETF is UCITS-compliant and has a straightforward equity exposure, the synthetic replication method and counterparty risk exposure are sufficient to classify it as complex under MiFID II.",
    "confidence": 85
}