{
    "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 complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which introduces counterparty risk and derivative exposure. While the fund itself is not leveraged or inverse, the use of swaps for replication and the emerging market focus (with associated liquidity and political risks) contribute to its complexity. The KIID explicitly mentions 'derivatives are integral to the Sub-Fund's investment strategies' and highlights counterparty risk as a material risk. The fact that it's a UCITS-compliant ETF doesn't automatically make it non-complex under MiFID II when synthetic replication is involved. The PRIIPs KID and factsheet confirm the synthetic replication method, which is a key complexity factor under MiFID II.",
    "confidence": 90
}