{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Derivative-related risks"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an OTC swap with Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the swap is used for replication rather than leverage or inverse exposure, the presence of derivatives and counterparty risk makes the product complex under MiFID II. The KIID and factsheet confirm the use of financial derivative instruments (FDIs) and highlight risks like leverage, high volatility, and valuation risk. The SRRI (risk level) is 3, indicating moderate risk, but the derivative structure and counterparty exposure elevate the complexity. The ETF is UCITS-compliant, which typically implies regulatory oversight, but synthetic replication with swaps is a MiFID II complexity trigger. The factsheet explicitly mentions counterparty risk and replication risk, reinforcing the classification.",
    "confidence": 90
}