{
    "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",
        "Emerging market complexity"
    ],
    "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 likely unfunded (standard for UCITS ETFs), the use of derivatives for replication triggers complexity under MiFID II. The underlying index (MSCI Emerging Markets Ex China) is also complex due to its emerging market focus, which may involve illiquid securities and higher volatility. The KIID explicitly mentions 'risk of financial derivative instruments' and 'counterparty risk', both complexity indicators. While the ETF has no leverage or inverse exposure, the combination of synthetic replication and emerging market focus makes it complex for retail investors.",
    "confidence": 85
}