{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk from derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which introduces counterparty risk and complexity beyond physical replication. While the underlying index (MSCI USA ESG Selection) is straightforward, the use of derivatives for replication triggers MiFID II complexity classification. The KIID explicitly states derivatives are integral to the strategy, and the fact sheet confirms synthetic replication. No leverage or inverse exposure is present, but the derivative-based structure and counterparty risk make this a complex product under MiFID II rules.",
    "confidence": 90
}