{
    "fund_name": "Xtrackers S&P Global Infrastructure 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",
        "Indirect replication (swap-based)",
        "Potential tracking error due to replication costs"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve exposure to the S&P Global Infrastructure Index. While it does not employ leverage or inverse strategies, the use of derivatives (specifically swaps) introduces counterparty risk and potential tracking error, which are key complexity factors under MiFID II. The KIID and PRIIPs documents highlight derivative risk and counterparty risk as significant considerations, reinforcing the classification as complex. The factsheet confirms the use of indirect replication via swaps, which is a common trigger for complexity in MiFID II assessments. The fund's risk profile (category 6) and the need for investors to understand derivative and counterparty risks further support this classification.",
    "confidence": 90,
    "counter_argument": "One could argue that the fund's straightforward index-tracking objective and lack of leverage or inverse strategies might suggest non-complexity. However, the explicit use of swaps for replication, combined with the associated counterparty and tracking error risks, outweighs this argument under MiFID II guidelines.",
    "risk_level": "6 (high risk)",
    "alignment_with_risk_profile": "The classification aligns with the fund's stated risk profile (category 6), as the use of derivatives and counterparty exposure introduces higher complexity and risk beyond simple physical replication."
}