{
    "fund_name": "Xtrackers FTSE Vietnam 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",
        "Emerging market complexity",
        "Indirect replication (swap-based)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the FTSE Vietnam Index, which introduces counterparty risk and complexity beyond physical replication. While the fund does not use leverage or inverse strategies, the swap-based structure and exposure to emerging markets (Vietnam) with potential liquidity and political risks contribute to its classification as complex. The KIID and PRIIPs documents highlight derivative risks, counterparty risk, and emerging market risks, which are key complexity indicators under MiFID II. The fact sheet confirms the use of derivatives for replication, reinforcing the complex classification.",
    "confidence": 90
}