{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) to track the MSCI Emerging Markets Net Total Return Index. While the fund does not employ leverage or inverse strategies, the use of derivatives (specifically swaps) introduces counterparty risk, which is a key complexity factor under MiFID II. The KIID explicitly mentions 'counterparty risk' as a material risk, and the fact sheet confirms the replication method is 'synthetic'. While the underlying index (emerging markets equities) is relatively straightforward, the synthetic structure and derivative exposure make this ETF complex under MiFID II rules. The UCITS compliance does not override the complexity classification when derivatives are used for replication rather than just risk management.",
    "confidence": 90
}