{
    "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",
        "Emerging market equities complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which introduces counterparty risk and derivative exposure. While the underlying index (MSCI Emerging Markets Latam) consists of straightforward equities, the use of swaps for replication makes the structure more complex. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and highlights counterparty risk, which are key complexity indicators under MiFID II. The fact that it's a UCITS-compliant ETF doesn't automatically make it non-complex, as synthetic replication with swaps typically triggers the 'complex' classification. The emerging market focus adds additional complexity due to higher market risks and potential liquidity challenges.",
    "confidence": 90
}