Comparative Analysis of Islamic Banking Supervision and Regulation Development

The paper highlights gaps in key areas of legislation, regulation and supervision, standard-setting of Shari‘ah-compliance and pinpoints areas where improvement is desirable to ensure stability in the Islamic banking and finance sector. The comparative analysis focuses on 11 selected Muslim countries (Malaysia, Iran, Bahrain, Saudi Arabia, Pakistan, Turkey, Indonesia, Sudan, Kuwait, U.A.E and Jordan) and two non-Muslim countries (Singapore and the United Kingdom). The findings suggest that the legislation for Islamic financial institutions in most countries is formulated in the image of conventional banking. Some countries lack proper legal framework with some notable issues including the lack of a dedicated Islamic banking law (Saudi Arabia), few laws relating to corporate governance (Iran, Bahrain, Kuwait, U.A.E). However, to date, most of countries follow the regulations of their domicile as well as International Accounting Standards (IAS). The paper also suggests that due to various difficulties to harmonize Islamic banking practices, facilitating cluster or regional convergence may be the first step towards greater harmonization for this sector.