{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Derivative use for efficient portfolio management, not central to strategy; no embedded derivatives, no leverage, no complex indices, no contingent convertible bonds, no swaps, no inverse structure",
    "supporting_data": "The ETF is a UCITS-compliant, physically replicated fund tracking the MSCI World Momentum Index. It uses derivatives (FDIs) for efficient portfolio management (EPM), such as managing inflows/outflows, hedging currency risk, or reducing transaction costs, but not as a central part of its investment strategy. The KID explicitly states that derivatives may be used for direct investment purposes, but the primary replication method is physical (holding underlying securities). There is no evidence of synthetic replication, embedded derivatives, leverage beyond UCITS limits, complex indices, or other features that would introduce structural complexity or opacity. The risks highlighted (market risk, index methodology risk, factor focus risk, counterparty risk from securities lending and derivative use) are standard for equity ETFs and do not indicate a complex structure under MiFID II. The fund engages in securities lending, but this is a secondary activity, well within UCITS rules, and does not dominate the risk profile. The ongoing charges are transparent, and there are no unusual exit fees or clauses that would alter the risk profile. The structure, risks, and objectives are described in a way that is likely to be understandable by a retail investor with basic knowledge.",
    "classification": "non-complex"
}