Abstract

Fueled by an increasing demand for investments that comply with Shariah (Islamic law), sukuk (Islamic investment certificates or participation certificates) have developed as one of the main components of the Islamic finance industry. In general, sukuk can be structured as asset based or asset backed, yielding wholly different risk profiles in the event of default and liquidation. However, given that the sukuk market is dominated by asset‐based sukuk, this article examines the motivation for greater interest in this specific sukuk structure. It also analyzes the challenges facing the regulatory framework and tax implemented for Islamic securitization in various jurisdictions. Then, it further evaluates, from the perspective of credit rating agencies, the importance of purchase undertakings in the structure and some controversies on this very point. The main issue that emerges is the difficulty of resolving the clash between the ideals of Islam and the realities of the marketplace. © 2015 Wiley Periodicals, Inc.

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