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OVERVIEW OF ISLAMIC FINANCE • OFFICE OF INTERNATIONAL AFFAIRS OCCASIONAL PAPER NO. 4 • JUNE 2006
Department o the TreasuryOfce o International AairsOccasional Paper No. 4August 2006
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Overview O Islamic Finance
DISCLAIMER
Occasional Papers rom the Treasury Department’s Oce o International Aairs exam-ine international economic issues o current relevance in an eort to identiy underlying trendsand issues or policymakers. These papers are not statements o U.S. Government, Depart-ment o the Treasury, or Administration policy and refect solely the views o their authors.
By Mahmoud Amin El-Gamal
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WhAt IS ISLAMIC FInAnCE?
Islamic nance started as a small cottage industry in some Arab countries in the late 1970s. It dis-tinguishes itsel rom conventional nance in itsostensible compliance with principles o Islamiclaw, or Shari’a.
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Its growth has been accelerating ever since, in terms o the number o countries in which it operates, as well as the areas o nancein which it has ventured. However, reliable dataare not available on Islamic nance at the coun-try, regional or global levels.
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In recent years, theindustry has attracted a number o western mul-tinational nancial institutions, such as Citigroupand HSBC, which started oering Islamic nan-cial products in some Arab countries (notably Bahrain and the United Arab Emirates), and to alesser extent in the western world (including theU.S., where HSBC oers various Islamic nancialproducts in New York, including home nancing,checking accounts, etc.). A number o Islamic -nancial products also involve the acquisition o assets (e.g., real estate, small corporations, etc.) inthe west (including the U.S.) in “Islamically struc-tured”nancing deals.Islamic nance relies crucially on three sets o in-dividuals with complimentary skills: (i) Financialproessionals who are amiliar with conventionalnancial products, as well as the demand or “Is-lamic”analogues o those products within vari-ous Muslim communities around the world, (ii)Islamic jurists (
 uqha
or experts on classical juris-prudence developed mainly between the 8th and14th Centuries), who help Islamic nancial pro- viders to nd precedent nancial procedures inclassical writings, upon which contemporary an-alogues o conventional nancial products can bebuilt, and (iii) lawyers who assist both groups instructuring Islamic analogue nancial products,
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This paper was originally written by the author in July 2004. Where necessary, the text has been updated by Treasury International Aairs sta, and the revised paper was reviewed and approved by the author.
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Mahmoud Amin El-Gamal is Proessor o Economics and Statistics at Rice University. He is Chair o Islamic Economics,Finance and Management in the Department o Economics. From May 2004 until December 2004 he was Islamic FinanceScholar-in-Residence at the U.S. Treasury Department.
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Shari`a literally means “the way”and is the Arabic term or Islamic Law as a way o lie, comparable to the Hebrew 
 Hal-achah
 ).
 Fiqh
 , commonly translated as jurisprudence, is the interpretation o Shari`a or specic circumstances by specialized
 uqha
 , or jurists.
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One can nd several quoted gures, used primarily or inormational purposes. However, there appears to be no reliablestatistical basis or those numbers, so we have to settle or qualitative growth description.
 
OVERVIEW OF ISLAMIC FINANCE • OFFICE OF INTERNATIONAL AFFAIRS OCCASIONAL PAPER NO. 4 • JUNE 2006
 while ensuring their compliance with all applica-ble and relevant legal and regulatory constraints.
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Due to the industry’s small size, a limited numbero key players in each o those three categorieshave emerged as clear leaders.
hIStoRICAL RootS oFISLAMIC FInAnCE
In the late 19th Century, the Ottomans intro-duced western-style banking to the Islamic worldto nance their expenditures. While some Islamic jurists approved o modern banking practices, themajority ound those practices to be violations o Islamic prohibitions against usury (Arabic term:
riba
 , equivalent to the Hebrew 
ribit 
 , and inter-preted in its classical Biblical sense o any interestcharge on loans, as opposed to the modern iden-tication o usury with exorbitant interest). Thisresentment continued through the Europeancolonial period, which lasted into the mid-20thCentury. Islamic revival played a central role inthe intellectual and social oundations o inde-pendence movements o the mid-20th Century.To many intellectual ounders o the movement,political independence was to be supplemented with economic independence, through the de-nition o an Islamic economic system.Early writings on what came to be known as “Is-lamic Economics”ocused on macroeconomicdevelopmental issues. By the 1970s, theoreticaldiscussions o Islamic economics had given riseto practical discussions o Islamic nance, whichturned juristic in nature: how can Muslims replace(conventional) nancial practices (deemed to beusury/
riba
-based) with Islamic alternatives. Mid-Century literature suggested a prot-and-losssharing silent partnership alternative to interest-based lending. The Arabic name o this contractis
mudaraba
 , which is akin to the medieval Eu-ropean
Commenda
contract, and the Jewish
 Heter  Isqa
 , designed similarly to avoid usurious lending in Jewish and early Catholic Law.
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 This partnership-based ocus survives in someIslamic nancial practices (e.g., as a substituteor interest-bearing bank deposits). However, with the help o Islamic jurists and lawyers, asdiscussed in the introduction, Islamic nancialpractitioners were soon able to provide close an-alogues to almost all nancial products, includ-ing various debt-instruments and xed-incomeinvestment vehicles. We shall summarize some o the most widely used Islamic nancial modes o operation in the ollowing section.
MoDES oF opERAtIon InISLAMIC FInAnCE
There are many contract and institutional ormsused within the industry collectively known as Is-lamic nance. Specics vary across countries andsectors. In this overview, we shall concentrate onsome o the basic and central modes o nanc-ing that are most popular in Islamic nance to-day. When signicant dierences exist betweenimplementations o a particular Islamic nancialtransaction in dierent regions or sectors, we notethose dierences briefy.
Csmer ad Bsiess LaAleraives
The juristic-based understanding o orbidden
riba
/usury suggested that Islamic nance has tobe “asset-based”, in the sense that one cannotcollect or pay interest on rented money, as onedoes in conventional banking. Thereore, the eas-iest transactions to Islamize were secured lending operations, e.g., to nance the purchase o realestate, vehicles, business equipment, etc. Threemain tools are utilized or this type o retail -nancing:
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In this regard, Islamic nance has to adhere to multiple legal requirements; or clarity, this paper will reer to religiousconstraints as “juristic”, and reserve the terms “legal”and “regulatory”or sovereign-imposed constraints.
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On
 Mudaraba/Commenda
 , see Udovitch, Abraham L.
 Partnership and Proft in Medieval Islam
. Princeton, N.J: PrincetonUniversity Press, 1970. On the Isqa (alternatively spelled Iska) contract, see Stern, J. “Ribit: A Halachic Anthology”,
 Journalo Halacha and Contemporary Society,
46, 1982. Sample Iska orms are available at:http://www.jlaw.com/Forms/iska_d.html.
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