{
    "fund_name": "Xtrackers MSCI Indonesia Swap UCITS ETF",
    "isin": "LU0476289623",
    "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 focus"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the MSCI Indonesia TRN Index, which introduces counterparty risk and complexity beyond physical replication. While the fund is UCITS-compliant and does not use leverage or inverse strategies, the reliance on derivatives for replication and exposure to emerging market risks (as highlighted in the risk profile) makes it complex under MiFID II. The KIID and PRIIPs KID emphasize counterparty risk and market concentration, further supporting the complex classification. The factsheet confirms indirect replication via swaps, reinforcing the synthetic structure.",
    "confidence": 90,
    "risk_level": "7 (high)",
    "counter_argument": "The fund is UCITS-compliant and does not use leverage or inverse strategies, which could argue for a non-complex classification. However, the synthetic replication method and counterparty risk override this argument, as MiFID II prioritizes derivative usage and risk transparency for retail investors.",
    "overriding_reason": "The use of swaps for replication and the associated counterparty risk are key factors in MiFID II's complexity assessment, regardless of UCITS compliance or lack of leverage."
}