{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure from swap agreements",
        "Currency hedging complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the TOPIX index, which introduces counterparty risk and complexity beyond direct physical replication. While the fund does not employ leverage or inverse strategies, the use of derivatives for replication purposes and the associated hedging mechanisms make it complex under MiFID II. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and highlights counterparty risk, which are key complexity indicators. The fact that the fund is UCITS-compliant does not negate the complexity arising from the synthetic structure. The PRIIPs KID and factsheet confirm the synthetic replication method and the use of swaps, reinforcing the classification.",
    "confidence": 90
}