{
    "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"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract with counterparties (Morgan Stanley Bank AG and Societe Generale), which introduces counterparty risk. While the fund is UCITS-compliant and does not use leverage or inverse strategies, the use of derivatives for replication (rather than physical holding of underlying assets) and the associated counterparty risk make it complex under MiFID II. The fact sheet confirms the swap usage and counterparty risk, which are key complexity indicators. The risk profile mentions financial derivative risks, including leverage, high volatility, and liquidity risks, further supporting the complex classification.",
    "confidence": 90
}