{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": "Swaps, Synthetic Replication, Counterparty Risk",
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS-compliant, passively managed fund tracking the MSCI ACWI Index. It uses synthetic replication via total return swaps with one or more counterparties to achieve its investment objective, rather than holding the underlying securities. This introduces counterparty risk, as the fund's performance depends on the swap providers fulfilling their obligations. The use of derivatives (swaps) is integral to the ETF's strategy, not merely for efficient portfolio management. The fund's documentation clearly states that the derivatives used may be adjusted to reflect certain expenses and that the fund may suffer a loss if a counterparty fails. These features make the structure, risks, and payoff of the ETF difficult for a retail investor with basic knowledge to understand, overriding the general UCITS presumption of non-complexity. The ETF does not use significant leverage beyond UCITS limits, does not engage in securities lending, and tracks a transparent, well-documented equity index. However, the central role of swaps and the associated counterparty risk are decisive in classifying this ETF as complex under MiFID II Article 57 criteria, as the structure is not straightforward and the risks are not easily grasped by the average retail investor."
}