For a complex product sold on a NON-ADVISED (execution-only) basis, the regime generally still requires the firm to:
Even without a recommendation, complex products trigger an appropriateness/knowledge check (e.g. CKA), so a client lacking the knowledge is warned or safeguarded - because complexity, not the advice, drives the risk of misunderstanding.
Execution-only does not remove the complex-product knowledge gate; appropriateness is still required.
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