{
    "type": "ETP",
    "ucits": false,
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": "Leverage, Synthetic replication via swaps, Counterparty risk, Daily reset compounding effect",
    "classification": "complex",
    "supporting_data": "The product is a GraniteShares 3x Long Amazon Daily ETP, which seeks to replicate 3 times the daily performance of Amazon via the Solactive Daily Leveraged 3x Long Amazon.com Inc Index. It uses a swap agreement with Natixis as the swap provider, indicating synthetic replication. The product employs significant leverage (3x daily leverage) with a daily reset, which introduces a compounding effect that can cause returns over periods longer than one day to deviate significantly from the underlying asset's performance multiplied by leverage. The swap structure introduces counterparty risk and collateral risk, which are complex features difficult for retail investors to understand. The product is explicitly stated to be high risk (7/7 risk class) and is intended for investors with specific knowledge or experience in similar products. The product is not UCITS compliant but an ETP. According to MiFID II rules and ESMA guidelines, such use of derivatives integral to the investment objective, synthetic replication, and significant leverage classify the product as complex. The presence of embedded derivatives (swaps), leverage beyond UCITS limits, and the synthetic replication method all contribute to this classification. The product's structure and risks are not straightforward for retail investors with basic knowledge, requiring an appropriateness assessment under MiFID II. Therefore, the product is complex under MiFID II criteria."
}