{
    "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 focus"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers CSI500 Swap UCITS ETF uses synthetic replication via swaps, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions derivative risk and counterparty risk as significant factors, which aligns with MiFID II's criteria for complexity. While the fund is UCITS-compliant and does not use leverage or inverse strategies, the use of swaps for replication and the emerging market focus (China A-shares) contribute to its classification as complex. The PRIIPs KID and factsheet confirm the swap-based structure and highlight risks like counterparty failure, further supporting the complex classification.",
    "confidence": 90
}