{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the MSCI Europe Momentum Index, which is a clear indicator of complexity under MiFID II. The KIID explicitly states that derivatives are integral to the investment strategy, and the use of indirect replication with counterparty risk exposure further supports this classification. While the fund does not employ leverage or inverse strategies, the synthetic nature of the replication and the associated counterparty risks make it complex for retail investors. The PRIIPs KID and factsheet confirm the synthetic replication method and the use of swaps, reinforcing the complexity determination.",
    "confidence": 90
}