{
    "type": "ETP",
    "ucits": false,
    "leverage": true,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Leverage 3x daily on underlying equity",
        "Synthetic replication via index with embedded leverage",
        "Daily rebalancing causing compounding effect",
        "High risk (7/7 risk indicator)",
        "No capital protection",
        "Potential counterparty and liquidity risks",
        "Complex payoff structure due to leverage and compounding"
    ],
    "classification": "complex",
    "supporting_data": "The product is a 3x leveraged Exchange Traded Product (ETP) on Moderna Inc. equity, aiming to deliver three times the daily performance of the underlying stock. It uses a synthetic replication method tracking the iSTOXX Leveraged 3x MRNA Index, which implies derivative usage integral to the investment objective. The product involves daily leverage rebalancing, leading to a compounding effect that can significantly deviate returns over holding periods longer than one day. The KID explicitly states the product is not simple and may be difficult to understand, with a highest risk class of 7/7. There is no capital protection, and the product exposes investors to market risk amplified by leverage. The use of derivatives and leverage, combined with the complex payoff profile and risks such as counterparty and liquidity risk, make this product complex under MiFID II criteria. According to MiFID II Article 254, Delegated Regulation EU 2017/565 Article 57, and ESMA guidelines, such features classify the product as complex, requiring an appropriateness assessment before sale to retail investors."
}