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The Central Bank of the UAE (CBUAE) continues to demonstrate a robust approach to regulation and supervision across the financial services sector in the UAE. Over the past twelve months, CBUAE enforcement actions have appeared in the headlines more frequently, sending a strong message to the market and emphasising the importance of compliance and consequences of non-compliance.

 

A turning point for Islamic Windows

On June 25, 2025, another enforcement headline surfaced, this time in the context of Shari’ah governance violations. According to the CBUAE, a Shari’ah supervision examination by the regulator revealed violations by an Islamic Window of a bank operating in the UAE. Consequently, the CBUAE has suspended the onboarding of new customers to the Islamic Window for six months and imposed a financial penalty of AED 3.5 million.

The regulatory expectations of Islamic Windows have been evolving over the past decade. Regulators and standard-setting bodies have been taking the necessary measures to ensure that the right governance and Shari’ah compliance frameworks are put in place by any financial institution partially conducting its business in accordance with the provisions of Islamic Shari’ah. For instance, in October 2020, the CBUAE issued standards regarding regulatory requirements for financial institutions housing an Islamic Window. These standards focused on critical areas that must be well managed and controlled by all institutions housing an Islamic Window, such as Shari’ah governance, systems, infrastructure, reporting, and asset and liability management.

Similarly, the Accounting and Auditing Organization for Islamic Financial Institutions (AAOIFI) stated that it approved in principle the exposure draft of its governance standard regarding the application of Shari’ah governance principles to Islamic Finance Windows. While the key principles of this standard are already adopted in various major Islamic finance jurisdictions, the standard provides a comprehensive overview of control expectations to be adopted by Islamic Windows.

 

Why robust Shari’ah governance matters

Taking into account the aforementioned standards, which are both applicable in the UAE among other Islamic finance regulatory mandates, Islamic Windows operating in the UAE should continue to monitor and assess their Shari’ah governance and compliance frameworks on a continuous basis. The Shari’ah governance framework of an Islamic Window is just as important as that of a fully-fledged Islamic bank, as the enforcement action by CBUAE proves that non-compliance leads to consequences significantly impacting the business and reputation of the organisation.

The importance of Shari’ah governance cannot be overstated. It ensures that Islamic financial institutions operate in accordance with Islamic principles, which is crucial for maintaining the trust and confidence of their customers. Effective Shari’ah governance involves not only compliance with regulatory standards but also the establishment of robust internal controls and risk management practices. This includes regular audits, continuous training for staff and the implementation of comprehensive policies and procedures.

 

Our approach to Shari’ah compliance

At Grant Thornton UAE, we specialise in advising institutions on Islamic finance regulatory requirements, with a proven track record in the UAE, GCC, and beyond, with a particular focus on the supervisory and policy-driven elements of Islamic financial services. Our team of experts is well-versed in the intricacies of Shari’ah governance and compliance, and we offer tailored solutions to meet the unique needs of each client.

Our solutions in this space include:

  • Independent assessment of Islamic Window operations
  • Regulatory examination preparation
  • Islamic Window design and operating effectiveness uplifting (including policies, procedures, manuals, and systems)
  • Islamic finance specialised training

In addition to these services, we also provide ongoing support to our clients in their journey, given the evolving regulatory and Shari’ah requirements. This includes regular updates on changes in regulations, assistance with the implementation of new standards, and continuous monitoring of compliance frameworks. Our goal is to help our clients navigate the complex regulatory landscape and achieve sustainable growth while maintaining the highest standards of Shari’ah governance.