{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an OTC swap with Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the swap is used for replication rather than leverage or inverse exposure, the presence of derivatives and counterparty risk makes this ETF complex under MiFID II. The KIID explicitly mentions 'Financial derivative Instruments' and 'Counterparty risk' as material risks. The fact sheet confirms the use of a swap for replication, and while the index (MSCI Brazil) is not inherently complex, the synthetic structure and counterparty exposure elevate the complexity. The ETF is UCITS-compliant, but UCITS status does not automatically exempt it from being classified as complex under MiFID II when derivatives are involved in the replication process.",
    "confidence": 90
}