Tuesday 11 April 2017

IFSA 2013; STEPPING STONE FOR MALAYSIAN FINANCIAL INSTITUTIONS DEVELOPMENT

2015
IFSA 2013; STEPPING STONE FOR MALAYSIAN FINANCIAL INSTITUTIONS DEVELOPMENT
Asmah Che Wan;
Nur Akmal Adnan;
Wan Nur Fatihah Mukhtar;
Nur Izzati Zafirah Zainal;
Nurulhaffizah Ahmad;
LLB (Hons) Students in Universiti Utara Malaysia
Supervised by Dr Mohd Zakhiri Md Nor[*]

Abstract
The regulatory framework for Islamic financial institution in Malaysia is perfectly enshrined with the introduction of new law of  the Islamic Financial Services Act 2013 on 30 June 2013, replacing the previous legislation which is Banking and Financial Institution Act (BAFIA) 1989. The new law is anticipating the sophisticated Malaysian financial industry running both the conventional and Islamic finance. Moreover, it foreruns the development Islamic financial operation in Malaysia by promoting financial stability and ensuring end-to-end Shariah compliance in the business activities[1]. As mentioned by Hakimah Yaacob in her article, “Cross Border Transaction In Islamic Finance: Standardisation Does Matter!”, the concept of standardisation is vital to denote on legal framework as it reflects on the uniformity of legal framework or interchangeable use with standardisation to govern transaction in Islamic finance. Therefore, this article would emphasize on the commencement of IFSA 2013 in the legal system and also on its effect towards the financial market in the country’s financial industry[2].

Introduction
Islamic banking and finance is a financial system which involves banking and financial dealings such as ethical investing, or ethical lending that is in compliance with the Shariah requirements. Its practitioners and clients need not be Muslim, but they must accept the ethical restrictions underscored by Islamic values[3]. The evolutionary process for the establishment of Islamic banking and finance system has taken quite some time. It started with the step taken by the Lembaga Tabung Haji (LTH) or formerly known as Perbadanan Wang Simpanan Bakal-Bakal Haji (Pilgrims Management and Fund Board). This is the first institution applying the Islamic transaction concept[4].  However, the community demanded for an Islamic bank and financial institution that was free from riba. Hence, on 30 July 1981, the Government appointed a National Steering Committee of Islamic Bank to establish an Islamic bank. Furthermore, the Committee proposed a basic framework of licensing and supervising of an Islamic banking system in Malaysia a year later[5]. On 7 April 1983, the Government passed the Islamic Bank Act 1983 (IBA) and this finally resulting into the establishment of the first model of Islamic bank in Malaysia, namely Bank Islam of Malaysia in July 1983[6].
The Central Bank of Malaysia (Bank Negara Malaysia) had undertaken a number of initiatives by introducing strategic and systematic reforms to the Islamic finance industry in Malaysia. These reforms include, the establishment of Malaysia International Islamic Financial Centre (MIFC), Islamic Financial Services Board (IFSB), International Centre for Education in Islamic Finance (INCIEF), International Islamic Liquidity Management Corporation (IILM), incorporating a relevant provision in the Rules of Court 2012 (late payment charge on judgment debt arising from financial transactions in accordance with Shariah), and introducing Legal Profession (Amendment) Act 2013 and the Islamic Financial Services Act 2013 (IFSA 2013). It is commonly acknowledged that IFSA 2013 provides the foundation for a comprehensive administration of Islamic financial system in Malaysia. Banking Act 1983 (IBA 1983) and the Takaful Act 1984 and consequently repealed both of them[7].

Application of Shariah
Practically, Malaysia is using dual financial system where it allows financing to be carried out via both conventional and Islamic methods. Since the Islamic financial system is still new in Malaysia as compared to the conventional one, the Islamic financing plays its functions by complementing the existing system and enacted new laws. At the same time, Malaysia also adopted dual court system, namely the Civil court and the Shariah court system[8]. The civil court jurisdiction is stated in the Federal List which includes banking, money lending, pawnbrokers and other similar instruments whereas, the Shariah court jurisdiction is stated under Item 1 of the State List that includes personal laws comprising of succession, testate and intestate, family law matters, gifts, wakafs and the determination of Islamic law and Malay custom and only practicable upon the Muslims.
Even though at the first glance, one may concluded that Islamic banking matter should be governs by the Shariah court, however that is not the situation here. Ironically, matters regarding Islamic finance are governed by the civil courts for the moment due to certain reasons. Firstly, issues on finance, such as banking, insurance and companies are part of the Federal List. Naturally, the parliament holds the power to enact laws on these matters. However, conflict arises when Islamic financial product has used the instruments under the jurisdiction of the State List in carrying out its transaction. While the whole process of banking should be within the Federal government power, the use of such instrument is clearly contradicting Article 121(1A) of the Federal Constitution. The issue then arises on which court has the jurisdiction to hear this kind of Islamic financial transaction? 
In regards to this matter, reference should be made to item 4(k) of the Federal List of the Ninth Schedule. Here, it mentioned on the power of parliament to enact laws on for ascertainment of Islamic law and other personal laws for purposes of federal law. Such power granted to the parliament shows that it is the power of the civil courts to adjudicate the matter. Thus, it would be best to invoke item 4(k) in answering to the abovementioned question.
This is because, it is very clear that any matter relating to Shariah is within the state jurisdiction, as stated in Item 1 of the State List. Item 1 of the State List covers very wide area that it gives the state the jurisdiction to determine any matters of Islamic law. Although it is very desirable to have such matter to be under the jurisdiction of the state, this would be difficult with the dual nature of Islamic banking (combination of conventional mechanism and Islamic principles of Muamalat). Therefore, the best way would be by invoking Item 4(k) of the Federal List.
Secondly, while the jurisdiction of Shariah court is restricted only to persons who professed the religion of Islam (Muslims), one cannot stop non-Muslims, companies, partnership and statutory bodies from getting involve with Islamic banking activities. That is exactly the situation at hand right now. Not to mention conventional banks, even Islamic bank is not to be considered as Muslims since they are not natural person. Such restrictions make it impossible for the Shariah court to have such jurisdiction as the nature of the court itself is unable to cover all the aspects that needs to be catered in order to discuss the problem.
To comprehend this issue, the Muamalat Bench was set up in 2003[9]. The bench, presided by a High Court Judge is located at the High Court Commercial Division 4. The set up marks the gradual fusion of the two systems into single system. As time goes by, we may be able to see a court system and procedure that able to handle cases according to common law, as well as the Shariah law. In addition, there has been proposal to introduce written substantive laws on Islamic matters.

Duties of Shariah Advisory Council (SAC)
The Shariah Advisory Council (SAC) was first established under the BAFIA 1989, operates to give advice to the Bank Negara Malaysia (BNM) and also the Islamic Banking Products and Services Bank (IBS). However, during the early days of its operation, the function of the SAC was strictly limited that its jurisdiction was not applicable to other Islamic finance institution or products such as the Islamic banks, Takaful operators as well as savings and development institutions.
The amendment of CBA 1958 BNM in 2003 gives SAC a wider room to practice its jurisdiction where, there are some new provisions construed, inter alia, section 16B, section 13A and subsection 16B(1) of  the CBA 2003. These gave the council more power and functions such as providing SAC the right to advise BNM on Shariah related matters which also bind all Islamic banking and financial matters, enabling Islamic banks to get advice from the SAC.
The Shariah Advisory Council had been mentioned in Section 51 to Section 58 of the Central Bank of Malaysia Act 2003 (CBA). These sections had outlined, among others, the establishment of the council itself, the council’s functions and also the effect of the rulings by the council.
The functions of SAC, as mentioned in Section 52 of the act, are as follows;
(1) to ascertain the Islamic law on any financial matter and issue a ruling upon reference made to it in accordance with Part VII of Central Bank of Malaysia Act;
(2) to advise the Central Bank on any Shariah issue relating to Islamic financial business, the activities or transactions of the Central Bank;
(3) to provide advice to any Islamic financial institution or any other person as may be provided under any written law; and
(4) such other functions as may be determined by the Central Bank.

Section 51 stated that the SAC is the authority that functioned to ascertain the Islamic rulings which will be referred to by the BNM and IFI. On the other hand, Section 52 of the act specifically mentioned on the functions of the council which is to ascertain the Islamic law on any financial matters and issue a ruling on it and advises the BNM on any Shariah issue relating to Islamic financial business, activities or its transactions. The section also gives power to the SAC to give advice to any Islamic financial institution or any other person.
Since the BNM is the sole body that regulates and supervises all the Islamic banking activities in Malaysia, the SAC that worked under the BNM is recognized as the supreme body in supervising the Islamic banking business of all the financial institutions that carried out business relating to Islamic financing.
Therefore, it is clear that the power to make rulings given to the SAC in Islamic Finance is vast. However, rulings are not always bound in the way that some may have choose to abandon the rules. Here one may question, whether the ruling made is binding and if it does, to what extent does it effective?
Section 55 provides that in any matters relating to Islamic finance and its business, the BNM should turn to the SAC for rulings and advice to ensure that any decision it made will not contradicts to the Shariah ruling. Apart from that, Islamic Financial Institutions (IFI) may take into consideration any published rulings of the SAC on Islamic finance and business matters. But, whether or not the court, in making decision, is bind to the rulings by the SAC, received conflicting views as some said that the provisions in Sections 56 and 57 of the Central Bank of Malaysia Act 2009 usurped the court’s judicial power and were therefore unconstitutional. The disagreement by the court on the ruling of SAC can be seen in the case of Arab-Malaysian Finance Berhad v. Taman Ihsan Jaya Sdn. Bhd. & 2 Ors[10] where it was held that the Bay' Bithaman Ajil contracts were null and void, which contradicts the ruling from SAC that approved such transaction. The court had refused to refer to the SAC by stating that there is no reason for the court to take into consideration the ruling that is not binding to it while making decision.
On the other hand, in the case of Tan Sri Abdul Khalid bin Ibrahim v Bank Islam Malaysia Bhd  & anor[11], the defendant provided two murabahah financing facilities to the plaintiff, enabling him to redeem and acquire more shares in a company. Due to some breaches by the plaintiff, the defendant offered to restructure the financing facility into BBA. In default of the first instalment, he then challenges the validity of the BBA facility agreement, alleging, non-compliance to principles of Shariah. Upon consultation with the SAC, the court decided in favour of the bank on matter regarding Shariah-compliant. The SAC has confirmed that BBA is Shariah-compliant. The learned judge, Rohana J said that there will always be differences in views and opinions on the Shariah, particularly in the area of muamalat, there will inevitably be varied opinions on the same subject. This is mainly due to the permissive nature of the religion of Islam in the area of muamalat. Such permissive nature is evidenced in the definition of Islamic banking business in Section 2 of the Islamic Banking Act 1983 itself. Islamic banking business is defined to mean, banking business whose aims and operations do not involve any element which is not prohibited by the religion of Islam. It is amply clear that this definition is premised on the doctrine of 'what is not prohibited will be allowed'. It must be in contemplation of the differences in these views and opinions in the area of muamalat that the Legislature deems it fit and necessary to designate the SAC to ascertain the acceptable Shariah position. In fact, it is well accepted that a legitimate and responsible government under the doctrine of Siasah-as-Shariah is allowed to choose, which amongst the conflicting views is to be adopted as a policy, so long as they do not depart from the Quran and Islamic injunction, for the benefits of the public or the ummah. Therefore, the designation of the SAC is indeed in line with that principle in Islam.
So, at this stage, the court is still on its discretionary power either to make reference to the SAC or not. Later, the situation changed with the enactment of the new Central Bank of Malaysia Act 2009, where Section 56 demanded all proceedings relating to Islamic financial business to consider the published rulings of the Shariah Advisory Council[12]. This is a departure from the previous stand in which the reference to SAC is on the discretion of the court.
Looking further into this matter, let us look at the role of the SAC in product development. Basically, product development is the creation of a new product or instrument to fulfil certain requirement. Here, the role of SAC is to give approval to the newly created product, as to whether it is Shariah compliance or not. Normally, the IFI prefer to present their product at the end of the process, when the product is almost ready. When presented, the council may make suggestion for improvement, or instead, suggest for a new product altogether. Following the suggestion from the SAC, the management is responsible to enhance its product. Only then, the product will be brought back to Shariah meeting to get the final Shariah endorsement. In reference to Section 57 of the CBA, any ruling made by the SAC shall be binding on the Islamic financial institutions. Therefore, only after the IFI managed to satisfy the requirement set up by the SAC in the meeting that the product will get the Council’s approval. 

Duties of Shariah Committee
In 2005, the Central Bank has prepared the Guidelines on the Governance of Shariah Committee for the Islamic Financial Institutions that regulates the governance of Shariah Committee of an Islamic financial institution. These Guidelines shall be applicable to all Islamic Financial institutions regulated and supervised by Malaysia Central Bank. The guidelines set the role, scope of duties and responsibilities of the Shariah Committee and its members and the relationship between the Shariah Committee of the respective Islamic financial institutions and the Shariah Advisory Board of the Central Bank.
It must be cognisant that the Shariah Committee (SC) has a direct duty upon the Banks and it shall be responsible and accountable for all its decisions, views and opinions related to Shariah matters. Board is expected to rely on the Shariah Committee on all Shariah decisions, views and opinions relating to the business of the Islamic financial institution. Also, the Shariah Committee is expected to disclose sufficient information in the Islamic financial institution’s annual financial report on the state of compliance of the institution to Central Bank.
SC is required to be independent within Islamic financial institutions through Islamic Banking Act 1983 and Takaful Act 1984. In 2004, the Guidelines on the Governance of Shariah Committee for the Islamic Financial Institutions has been issued outlining the role, duties and responsibilities of Shariah committee and its members as well as the relationship and working arrangement between the Shariah committee at individual institutions and the Shariah Advisory Council at the national level. The Guidelines, among others, prohibit individuals from sitting in more than one committee within the same industry to avoid a conflict of interest. The rule served as a stimulant in expanding the pool of Shariah talent within the Islamic financial industry  and increasing its diversity in terms of the experience and expertise of Shariah experts. Today, the total number of Shariah scholars has increased to more than a hundred individuals from a small number of experts when the Guidelines was first issued on December 2004. Although the current Shariah governance structure has increased the eminence of the role of the Shariah committee within the Islamic financial industry, the further improvements to the Guidelines are needed to take into account the rapid developments in Islamic finance in this recent few years. These include, the enrichment relating to the governance arrangements of the board and management in respect to the Shariah compliance process, the strengthening of internal research capacity, the independence and accountability of the Shariah committee in the decision making process, compliance and the risk management processes.
The duties and responsibilities of the Shariah Committee are commanded by the Shariah Governance Framework for Islamic Financial Institution issued by the Bank Malaysia (BNM). Among the function of Shariah Committee include to advice the Board on Shariah matters in its Islamic business operations. Here, the Shariah Committee have a duty to advise the Board of Directors in Islamic financial institutions on Shariah matters in order to assure that the Islamic business operations of Banks always comply with Shariah principles. Secondly, Shariah Committee has responsibility to endorse Shariah policies and procedure in each Islamic Banks. This is under the reason to ensure that Shariah policies and procedures do not contain elements which are not in line with Shariah. Third, to endorse and validate relevant documentations. The Shariah Committee shall ensure that the Islamic finance products of Export and Import Bank (EXIM Bank), in all aspect, comply with Shariah principles. Shariah Committee must ensure that the terms and conditions contained in the proposal forms, contracts, agreements or other legal documentations used in executing the transactions, and also, the product manual, marketing advertisements, sales illustrations and brochures used to describe the product in line with Shariah principles.
Apart from that, Shariah Committee also has duty in assisting related parties on Shariah matters. The Shariah Committee may provide assistance to relevant parties such as its legal counsel, auditor or consultant to ensure compliance with Shariah principles. Also, Shariah Committee has a duty to look over or assess work carried out by Shariah review, research, compliance and audit functions in order to ensure compliance with Shariah matters in its Islamic business operations[13].
Furthermore, in order to ensure compliance with Shariah matters, Shariah Committee also need to assess work carried out by Shariah review and Shariah audit which forms part of their duties in providing their assessment of Shariah compliance and assurance information in the annual report. Apart from that, the Shariah Committee may also advise the Bank to consult the Shariah Advisory Council of Bank Negara Malaysia (SAC of BNM) pertaining Shariah matters that could not be resolved. In cases where there are uncertainties and varieties of opinions, the Bank may seek advice and refer for a ruling from the SAC. The application for advice shall be communicated through the Secretariat of the SAC. It must be noted that members of the Shariah Committee must not act in any manner that would undermine the rulings and decisions made by the SAC of BNM or the committee they represent. Also, they are enforced to respect and observe the published Shariah rulings issued by the SAC, and shall not go against the decisions of the committee that they represent in public. In cases of disputes and court proceedings relating to Islamic financial business or any Shariah matters arising from the Bank’s business operations, both the court and the arbitrator shall take into deliberation the published rulings of the SAC or refer such issues to the SAC for its ruling. Any ruling made by the SAC arising from a reference made to them shall be binding on the Bank and the court or the arbitrator. On the other hand, in the event where the decision given by the Bank’s Shariah Committee is different from the ruling given by the SAC, the rulings of the SAC shall prevail. However, the Shariah Committee is allowed to adopt a more strict Shariah decision.
In addition to that, Shariah Committee also need to provide the Bank with guidelines and advice on religious matters to ensure that the Bank’s overall activities are in line with Shariah and also make decisions on matters arising from existing and future activities of the Bank which have religious repercussions. It is also their duty to report to the shareholders and the depositors that all the Bank’s activities are in accordance with Shariah as well as represent the Bank or to attend any meetings with the SAC or other relevant bodies concerning any Shariah issues relating to the Bank. Also, the Shariah Committee has a duty and responsibility to ensure the quality and consistency of the Shariah decisions[14].
It is pertinent to know that the role and function of the Shariah committee has been expanded further from merely advisory in nature to assume a higher degree of accountability. Throughout the Islamic financial institution, the Shariah committee will now be accountable for the implementation of decisions and opinions. Also, the Shariah committee shall have direct access to the board. The Shariah committee shall also report directly to the Bank where the committee believes that non-compliances on Shariah matters in the Islamic financial institution have not been effectively and sufficiently addressed by the Islamic financial institution.

Shariah Committee under IFSA 2013
Under Islamic Financial Services Act 2013 (IFSA 2013), the rule relating to Shariah governance is stipulated under Section 30 until Section 36 of IFSA 2013. These provisions, highlighted the intention of the law maker in focusing to the matters relating to appointment and qualification of the Shariah Committees members in Islamic financial institution. Even though Central Bank of Malaysia Act 2009 (CBA 2009) already touched the Shariah Committee matters, however it was only merely mentioned by highlighting the general requirement for financial institution to have a Shariah committee. The current provision under IFSA 2013 provides a more specific requirement under Section 30 which requires an institution to apply directly to the Central Bank for the establishment of Shariah Committee. This will enable the Central Bank to have direct information as to the members of the Shariah Committee in an Islamic financial institution will give a proper supervision towards the activities conducted.
On the other hand,  a clear standard of requirement pertaining to the appointment of such committee is highlighted under Section 31 which is to be crossed referred with Section 29(2)(a). This provision makes it clear that only those who is really fit and qualified may be appointed as the Shariah Committee members. The qualifications of the members must meet the requirements as stated by Central Bank. These requirements is important to ensure the products and services introduced by the Islamic financial institution in line with the Shariah principles. Meanwhile, Section 32 of IFSA 2013 stated about the importance of Shariah Committees in every institution through the introduction of the Shariah governance which not only set out the duties of the Shariah committees in the institutionbut also blend into the structure of the company itself. It must be noted that by extending the powers of Shariah governance into certain aspects in a company, we can understand that Shariah governance would be one of the integral parts in an institution, not just a minor part.
Apart from that, Section 33 and 34 of IFSA allowing the Central Bank to continuously be updated by the institution of its Shariah Committee members. In order to maintain the standard of Shariah Committee member, the provision set out the clause relating to the cessation of the members including situations which would disqualifies them from becoming Shariah committee members. By regulating precise rules and regulations, Section 35 has made it compulsory for management in charge of the company to provide information to the Shariah committee to exercise its task and duties. In plus, Section 36 marks the trust which has been given by the legislation over the Shariah Committee to keep any type of information provided that such information is not being relayed to the other persons and shall be confidential.
It must be noted that while maintaining the duty of confidentiality, in the Shariah Proceeding of the World Conference on Integration of Knowledge, members are vested with the protection under the qualified privilege to avoid them from being taken a legal action by the Islamic financial institution. This can only be prevented if it can be proven that such duties was conducted in good faith. This is to ensure that the activities of the Islamic financial institution is in accordance with Shariah compliance, while protecting the qualified members and thus maintaining a good Shariah governance framework in Islamic financial industry in Malaysia.

The Importance of Supervision
There are few significants of supervising bank through Shariah Committee and Syariah Advisory Council. Firstly from all, it must be cognisant that documents or instruments to be used in Islamic banking transactions have to be in accordance with Islamic law, existing civil law, and also to be structure in a way as to be enforceable in the civil courts.[15] Therefore, in order to strengthen the Shariah governance structure in Islamic financial institutions, the institution by issuing a new Shariah governance framework, must be supervised by members of Shariah Committee so that all the products, transactions and contract is in line with Shriah principles, as well as in accordance with the civil law itself. This supervision is also to provide comprehensive guidance to the board. Besides, the duty of Shariah Committee and management of Islamic financial institutions is important to ensure proper functioning of Shariah compliance through effective Shariah review and Shariah audit functions[16].
Apart from that, compliance to Shariah is vital to enhance the confidence of the stakeholders of Islamic financial institutions. In this regard, the IFSA provides a comprehensive legal framework that is in full compliance with Shariah in all aspects of regulations and supervisions of the Islamic financial institutions in Malaysia. It provides from licensing to the winding up of the Islamic financial institutions. It must be noted that in order to build public confidence in the system, this is one of the key areas in the evolution of the legal framework for Islamic finance in Malaysia which aims to provide greater certainty and predictability to the Islamic financial institutions. Also, this is essential to allow the Islamic financial system in Malaysia to face the new challenges and demands for financing associated with Malaysia's economic transformation programme in the future and the increasing integration of the Malaysian economy with the region and the world[17].



The Legal Framework in Malaysia
The regulatory framework in Malaysia has been enhanced and developed with the objective to promote financial stability and ensure Shariah compliance in the business activities of the Islamic financial institutions. As all know, IFSA is the new laws that came into force on 30 June 2013 to replace the previous legislation which is Banking and Financial Institution Act (BAFIA) 1989.
BAFIA which came into force on 1st October 1989 was legislation with the objectives to provide laws for the licensing and regulation of the institutions carrying on banking, finance company, merchant banking, discount house and money-broking business, for the regulation of institutions carrying on certain other financial businesses, and for the matters incidental thereto or connected therewith. BAFIA also was a legislation which provide for an integrated supervision of the Malaysian financial system and also to provide the Central Bank with the power to speedily investigate and prosecute, if necessary any illegal activities in an attempt to reduce white-collar crime[18]. This is different with IFSA which was enacted with the objectives to govern the matter pertaining to appointment and qualification of the Shariah Committees members in Islamic financial institution. IFSA also give the opportunity for the development of an end-to-end Shariah compliant regulatory framework for the conduct of Islamic financial operation in Malaysia[19].
The operation of the Islamic financial system and Islamic Banking Business are regulated by the Central Bank of Malaysia through the Central Bank of Malaysia Act 2009 (Act 701) together with the Islamic Financial Services Act 2013 (IFSA).
·         The Central Bank of Malaysia Act 2009 (Act 701)
This act was passed to provide for the continued existence of the Central Bank of Malaysia and for the administration, objects, functions and powers of the Bank, for consequential or incidental matters. The new legislation is intended to resolved the issue that arises prior of the Act. Section 51 until Section 58 in Part VII of the Act explains about the Shariah Advisory Council while Section 59 to Section 60 mentions on the Powers of the Bank.
According to section 51 of the Act, the Central Bank of Malaysia shall appoint the Shariah Advisory Council (SAC) and the SAC will be the authority to ascertain Islamic law in the Islamic financial business. In addition, Section 52 and 53 states about the function of the of the SAC and the appointment of the members of the SAC, respectively.
The Bank shall consult the Shariah Advisory Council  on matter relating to Islamic financial business and for the purpose of carrying out its function or conducting its business as stated in section 55 of the Act. Section 56(1) expressly states on the requirements for reference to SAC for purpose of rulling from court. The provision requires the judge who is conducting any issue arising from Islamic financial business to refer to the published rulings of the Shariah Advisory Council or to request for advice from the Council to determine any issue concerning a Shariah matter before them.
Other than the provisions as provided in the Central Bank of Malaysia Act 2009, the Bank also provides Shariah Governance Framework as a guidelines. In 2011, The Central Bank implements the Shariah Governance Framework for the Islamic Financial Institutions which requires all Islamic financial institutions to comply with the framework. The framework requires accountability and responsibility by the Board of  Directors to make sure the compliance of the Shariah governance framework in Islamic financial institutions.

·         Islamic Financial Services Act 2013
IFSA’s principle regulatory objectives are to promote financial stability and compliance with Shariah (Sec 6 of IFSA). The said requirements related to Shariah compliance and governance is highlighted under Part IV. It has three divisions as follows:
I.                   Shariah Compliance: The rules relating to Shariah compliance is provided under section 27 until section 29 of IFSA 2013.
Section 27 of the Act explains on the interpretation of intuitions which refers to an authorised person or operator of a designated payment system. Meanwhile, section 28 elaborates about the duty of institution to ensure compliance with Shariah. Here, the Islamic financial intitution must ensure at all times their operations, business, affairs or activities are in compliance with Shariah. Section 29 which is related to power of Bank (BNM) specifies the standards on Shariah matters. The Central Bank of Malaysia will issue specific standards on Shariah matters in respect of the carrying on of business, affair or activity with the advice or ruling of SAC.
II.                Shariah Governance: The rule relating to Shariah governance is provided under section 30 until section 36 of IFSA 2013.
Section 30(2) provided that, a financial group may apply to BNM for a single Shariah Committee to oversee its Islamic financial services and banking business if BNM is satisfied that the Shariah Committee has the capability to ensure Shariah compliance. Section 31 and 33 of the IFSA 2013 explain the standard of requirements for the appointments of Shariah Committe in financial intitutions. Any appointment or termination of a Shariah committee member must be with prior written approval of BNM. Under section 35 of the Act, all information submitted to the Shariah committee shall be accurate, complete, not false or misleading in any material particular. Section 36 of the Act, give the duty of confidentiality towards the Shariah Committee to hold any type of information including the confidential ones Members of the committee and would not be liable to defamation suit for any statement made in discharge of its duties without malice.
III.             Audit: The rule relating to audit provided under sections 37 and 38 of IFSA 2013.
Under section 37 and 38 of the IFSA 2013, The Central Bank of Malaysia (BNM) may require the Islamic financial institution to appoint any person as the BNM may approve to carry out an audit on Shariah compliance by the Islamic financial constitution. The external auditor may report to BNM on any findings and cost to be borne by the Islamic bank.
As we can see from the legal framework of IFSA, there are few special features of the IFSA 2013. Firstly, IFSA is the legislation that has all the matters contain in several legislation that Malaysia use before such as, Islamic Banking Act 1983, the Takaful Act 1984, the Payment System Act 2003 and the Exchange Control Act 1953. This can be seen in several sections under IFSA 2013. For example section 4 of the Act explains about a bank may with a concurrence of a minister prescribe the (a) qualified financial agreement; (b) financing facilities and (c) market participant.
Another section is, section 7 of the act which explains a matter regarding the powers and function of the bank. This section has to be read together with section 3(5) and section 5 of the Central Bank of Malaysia Act 2009. Next speciality under the IFSA 2013 is, under section 10, it explains about a grant of license by minister. If the license was granted, the applicant shall carry out its licensed business within a period of time that shall be specified by the minister. There are more sections under the IFSA that make this new laws are better that the previous one such as section 25 which explains matter regarding holding out as authorized person, section 26 matter regarding acting on behalf unlicensed person and section 29 matter regarding power of bank to specify standard on Shariah matters.
Furthermore, the implementation and administration of the law is more transparent and clear. The regulatory objectives and accountability of Bank Negara Malaysia in pursuing its principal object to safeguard financial stability, transparent triggers for the exercise of Bank Negara Malaysia's powers and functions under the law, and transparent assessment criteria for authorizing institutions to carry on regulated financial business, and for shareholder suitability are also being define clearly under this new statutory[20]. Besides that, IFSA 2013 is focusing on Shariah compliance and governance in the Islamic financial sector. In other words, the IFSA provides a comprehensive legal framework which fully consistent with Shariah in all aspects of regulation and supervision, from licensing to the winding-up of an institution[21].

Legal Analysis
Looking into a recent case on Islamic Banking, Bank Kerjasama Rakyat Malaysia Bhd v. Brampton Holdings Sdn Bhd[22] where in this case, the court allow this application with costs as the defendant has failed to discharge its burden to raise a triable issue in this case. The plaintiff, at the request of the defendant, granted the defendant a Term Financing-I Facility ('Islamic Financing Facility'). Accordingly, a letter of offer was issued by the plaintiff to the defendant which provided for two tranches of Islamic financing ie, (i) tranche 1 of RM35 million ('Tranche 1') based on the Islamic principle of Bai' Bithaman Ajil ('BBA') and (ii) tranche 2 of RM10 million ('Tranche 2') based on the Islamic principle of Bai' Al-Inah ('BAI'). For both tranches, an asset purchase agreement ('APA (BBA)') and an asset sale agreement ('ASA (BBA)') was agreed and entered into by the plaintiff and defendant. However, the defendant failed to make the required payments as agreed ('defendant's breach'), the plaintiff demanded from the defendant, the total outstanding sum of RM44,276,675.35 and compensation amount for late payment (ta'widh ) calculated at the rate of 1% per annum on the sum of RM44,276,675.35.
As the defendant did not reply to the plaintiff's demand, hence, the plaintiff filed the present suit against the defendant and claimed the outstanding sum and compensation on the outstanding sum. The defendant resists this application on few issues. Nonetheless, the main highlight is on the claim of "extra" sums of RM490,000 (for Tranche 1) and RM140,000 (for Tranche 2) in which the alleged excess constitutes interest (riba ) which is prohibited in Islam. Therefore this taints the Islamic Financing Facility in this case and renders the Islamic Financing Facility unenforceable. The defendant's failure to deny the plaintiff's demand means that the defendant admits the defendant's default and the attendant liability as there had never been an agreement. So, it is reasonable to expect a prompt and vigorous denial.[23]
In Bank Islam Malaysia Bhd v. Lim Kok Hoe & Anor and Other Appeals[24], at pp. 35, 36 and 39-40, Raus Sharif JCA (as His Lordship then was) mentioned that there is  no hesitation in accepting that riba' or interest is prohibited in Islam. However, such comparison between a BBA contract and conventional loan agreement was inappropriate as these two instruments of financing are not alike and have different characteristics. BBA contract is a sale agreement whereas a conventional loan agreement is a money lending transaction. The profit in BBA contract is different from interest arising in a conventional loan transaction.
Some authorities that are used in Lim Kok Hoe in the Court of Appeal's judgment are Section 51(1) of the Central Bank of Malaysia Act 2009 (CBMA) provides for the Shariah Advisory Council on Islamic Finance (SAC) to be set up by Bank Negara Malaysia (BNM) and SAC "shall be the authority for the ascertainment of Islamic law for the purposes of Islamic financial business". Also, reference made to few relevant provisions in Islamic Financial Services Act 2013 (IFSA) such as under Section 28(1) of the IFSA, a financial institution "shall at all times ensure that its aims and operations, business, affairs and activities are in compliance with Shariah". According to Section 28(2) of the IFSA, compliance with any ruling of SAC "in respect of any particular aim and operation, business, affair or activity shall be deemed to be a compliance with Shariah in respect of that aims and operations, business, affair or activity". Any person who breaches Section 28(1) of the IFSA commits an offence under Section 28(5) of the IFSA which is punishable up to eight years imprisonment and a fine not exceeding RM25 million or both;
Meanwhile, Section 29(1)(a) of the IFSA states that BNM may in accordance with SAC's advice or ruling, specify standards on Shariah matters in respect of the carrying on of business, affair or activity by a financial institution which requires the ascertainment of Islamic law by the SAC. Any person who fails to comply with any standards specified under Section 29(1), commits an offence under Section 29(6) of the IFSA and shall, on conviction, be liable to imprisonment for a term not exceeding eight years or to a fine not exceeding RM25 million or both. Besides that, a financial institution shall establish a Shariah committee under Section 30(1) of the IFSA to advise the financial institution so as to ensure that the financial institution's business, affairs and activities comply with Shariah.
After a review has been made on the case Bank Kerjasama Rakyat Malaysia Bhd v. Brampton Holdings Sdn Bhd[25], it can be observed here that the application of IFSA 2013 is evolving. Also, the initiative taken by the court in order to improve in the interpretation of law finally gives light at the end of the tunnel particularly on the development of the law of Islamic Banking and Finance itself. Based on CBMA and IFSA, a court cannot simply decide that an Islamic financing facility is not Shariah compliant. Instead, the court should be guided by the advice and ruling of the SAC.
Other than that, Section 32 of IFSA 2013 is extending the powers of Shariah governance into matters involving the board of directors and internal Shariah compliance. This proves that Shariah governance would be one of the integral parts in an institution up to the point that Shariah committee may no longer be treated as a minor part or division of a company, what more against the idea of abandoning such governance rules.
Generally, the Section 37 provides that the Bank may appoint for an institution “any person” to conduct an audit on Shariah compliance. Since there is no specific requirement is needed for a person to do the audit, it is said to be a loopholes in this law. This is because any person would not have an adequate knowledge on Shariah matters. Looking this as an essential aspect, it is brilliant if Malaysia can produce more experts in this field. As for us as law students, we are in our view that every law school in Malaysia need to make Islamic Banking subject as a compulsory subject rather than an elective subject. This is for the benefit of all especially financial institution.



Conclusion
Malaysia's Islamic banking and finance industry has been in existence for over 30 years, starting with the establishment of the first Islamic bank in 1983. Thereupon, IFSA 2013 is a great stepping stone to enhance the development of financial industry in Malaysia and this shifted the legal framework and legislation in Malaysia to the next level. It provides comprehensive law governing on Islamic Banking and Finance which therefore indirectly promotes financial stability and ensures end-to-end Shariah compliance in the business activities.

References
Online Sources
Islamic Banking. Institute of Islamic Banking and Insurance (IIBI). Retrieved December 9, 2015, from http://www.islamic-banking.com/what_is_ibanking.aspx
Muhammad Amrullah Nasrul, & Surianom, M. (n.d). Shariah governance in Islamic finance: The effects of Islamic Financial Services Act 2013. Retrieved on 3rd December 2015, from http://worldconferences.net/proceedings/wcik2013/toc/papers_wcik2013/WCIK%20112%20SURIANOM_read_shahrul.pdf
(n.a.). (n.d.). EXIM Bank Malaysia: Roles and responsibilites. Retrieved on 3rd December 2015, from http://www.exim.com.my/about-us/shariah-committee
(n.a.). (n.d.). Duties and resposibilities of the Shariah Committee. Retrieved on 3rd December 2015, from http://www.muamalat.com.my/downloads/corporate-overview/Duties-and-Responsibilities-of-the-Shariah-Committee.pdf
(n.a.). (n.d.). The new Shariah framework. Retrieved on 3rd December 2015, from http://www.bnm.gov.my/files/publication/fsps/en/2009/cp03_003_whitebox.pdf
The Lawyerment | The Banking and Financial Institutions Act 1989. Retrieved on 26th November 2015, from http://www.lawyerment.com.my/financial/banking2.shtml

Journal
Hakimah Yaacob. (2012). Cross Border Transaction In Islamic Finance: Standardisation Does Matter! Malayan Law Journal Articles. Vol. 5 (lxxxvi). Retrieved December 10, 2015, from Lexisnexis Malaysia Sdn Bhd.
Mohamed Ismail Shariff. (1998). The development of Islamic banking law in Malaysia. Malayan Law Jurnal Articles.[1998] 1 MLJ cxlv. Retrieved on 3rd December 2015, from LexisNexis Malaysia Sdn Bhd.
Ruzian Markom, & Norilawati Ismail. The development of Islamic Laws in Malaysia; An overview. [2014] 1 LNS(A) xxviii
Tun Arifin Bin Zakaria. (2013). A Judicial Perspective On Islamic Finance Litigation In Malaysia. IIUM Law Journal. (21 IIUMLJ 143). Retrieved December 8, 2015, from Ahmad Ibrahim Kulliyyah of Law Website. p 148.
Zamri bin Hassan. (2002). Islamic Banking: Its Legal Impediments and Reformation With Special Reference to Malaysia. Law Majalla. Vol. 1, p. 97.

Books
Joni Tamkin Borhan. (2005). Pelaksanaan Prinsip-Prinsip Syariah Dalam Amalan Perbankan Islam di Malaysia, in Abdullah Alwi Hj. Hassan (Ed.), Teori dan Aplikasi Kontemporari Sistem Ekonomi Islam di Malaysia. Kuala Lumpur: Utusan Publication, p. 44.
Mohammad Rizal Salim, K. Sherin & Lim S. H. (2014). The Parallels of Shariah Governance and Corporate Governance: A Malaysian Case Study. [2014] LR 47. Thomson Reuters Malaysia Sdn Bhd (trading as Sweet & Maxwell Asia).
Nik Norzrul Thani, Mohamed Ridza Mohamad Abdullah, Megat Hizaini Hassan, 2003, Law and Practice of Islamic Banking and Finance, Sweet and Maxwell Asia, Selangor p 11.



[*] LL.B(Hons),LL.B(Shariah)(Hons),MCL, Civil & Shariah Law in International Islamic University; INCEIF,The Global University In Islamic Finance Education; Ph.D, In Islamic Finance; Legal Advisor; Research Fellow Institute for Governance and Innovation Studies; Assistant Professor in Universiti Utara Malaysia.



[1] Read more at:- www.inceif.org
[2] Hakimah Yaacob. (2012). Cross Border Transaction In Islamic Finance: Standardisation Does Matter! Malayan Law Journal Articles. Vol. 5 (lxxxvi). Retrieved December 10, 2015, from Lexisnexis Malaysia Sdn Bhd.
[3] Islamic Banking. Institute of Islamic Banking and Insurance (IIBI). Retrieved December 9, 2015, from http://www.islamic-banking.com/what_is_ibanking.aspx
[4] Joni Tamkin Borhan. (2005). Pelaksanaan Prinsip-Prinsip Syariah Dalam Amalan Perbankan Islam di Malaysia, in Abdullah Alwi Hj. Hassan (Ed.), Teori dan Aplikasi Kontemporari Sistem Ekonomi Islam di Malaysia. Kuala Lumpur: Utusan Publication, p. 44.
[5]  Zamri bin Hassan. (2002). Islamic Banking: Its Legal Impediments and Reformation with Special Reference to Malaysia. Law Majalla. Vol. 1, p. 97.
[6] See Nik Norzrul Thani, Mohamed Ridza Mohamad Abdullah, Megat Hizaini Hassan, 2003, Law and Practice of Islamic Banking and Finance, Sweet and Maxwell Asia, Selangor p 11.
[7] Tun Arifin Bin Zakaria. (2013). A Judicial Perspective On Islamic Finance Litigation In Malaysia. IIUM Law Journal. (21 IIUMLJ 143). Retrieved October 17, 2015, from Ahmad Ibrahim Kulliyyah of Law Website. p 148.
[8]Ruzian Markom & Norilawati Ismail. The development of Islamic Laws in Malaysia; An overview. [2014] 1 LNS(A) xxviii
[10] [2008] 5 MLJ 631
[11] [2009] 6 MLJ 416. See also Mohd Alias Ibrahim v RHB Bank Bhd & Anor.
[12] Mohammad Rizal Salim, K. Sherin & Lim S. H. (2014). The Parallels of Shariah Governance and Corporate Governance: A Malaysian Case Study. [2014] LR 47. Thomson Reuters Malaysia Sdn Bhd (trading as Sweet & Maxwell Asia).
[13] (n.a.). (n.d.). EXIM Bank Malaysia: Roles and responsibilites. Retrieved on 3rd December 2015, from http://www.exim.com.my/about-us/shariah-committee
[14] (n.a.). (n.d.). Duties and resposibilities of the Shariah Committee. Retrieved on 3rd December 2015, from http://www.muamalat.com.my/downloads/corporate-overview/Duties-and-Responsibilities-of-the-Shariah-Committee.pdf
[15] Mohamed Ismail Shariff. (1998). The development of Islamic banking law in Malaysia. Malayan Law Jurnal Articles.[1998] 1 MLJ cxlv. Retrieved on 3rd December 2015, from LexisNexis Malaysia Sdn Bhd.
[16] (n.a.). (n.d.). The new Shariah framework. Retrieved on 3rd December 2015, from http://www.bnm.gov.my/files/publication/fsps/en/2009/cp03_003_whitebox.pdf
[17] Muhammad Amrullah Nasrul, & Surianom, M. (n.d). Shariah governance in Islamic finance: The effects of Islamic Financial Services Act 2013. Retrieved on 3rd December 2015, from http://worldconferences.net/proceedings/wcik2013/toc/papers_wcik2013/WCIK%20112%20SURIANOM_read_shahrul.pdf
[18] The Lawyerment | The Banking and Financial Institutions Act 1989. Retrieved on 26th November 2015, from http://www.lawyerment.com.my/financial/banking2.shtml
[19] See Surianom Miskam and Muhammad Amrullah NasrulShariah governance in Islamic finance: The effect of the Islamic Financial Services Act 2013, p 98.
[20] (n.a.). (2013). Financial Services Act 2013 and Islamic Financial Services Act 2013 Come Into Force. Retrieved on 28th November 2015, from http://www.bnm.gov.my/index.php?ch=en_press&pg=en_press_all&ac=2837
[21] Ibid
[22] [2015] 4 CLJ 635; [2015] 1 LNS 67
[23] Refer David Wong Hon Leong v. Noorazman Adnan [1995] 4 CLJ 155 and JEC Designabuild Sdn Bhd v. Bunga Kembang Sdn Bhd [2007] 1 AMR 578.
[24] [2009] 6 CLJ 22
[25] [2015] 4 CLJ 635; [2015] 1 LNS 67

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