SHAA 5351

AL-MU'AMALAT AL-MALIYYAT WA AL-MASRIFIYYAT

AL-ISLAMIYYAT

SEMESTER 2, SESSION 2024/2025

AHMAD IBRAHIM KULLIYYAH OF LAWS

Written Assignment: Sukuk Murabahah

Due date: 2nd June 2025

Instructor’s Name: Dr. Mohamed Ibrahim Negasi

Group Members:

NO. NAMES MATRIC NUMBERS

1 Nur Syafiqah binti Shaharudin 52010004

2 Nur Fahwa Fitnina binti Juraish 52011802

3 Ahmad Mujtaba bin Abdullah Bukhari 52012999

 Index

Index................................................................................................................................................1

1.0 Introduction..............................................................................................................................2

2.0 Overview of Sukuk Murabahah............................................................................................. 2

3.0 Types of Sukuk......................................................................................................................... 3

4.0 Shariah rulings on Sukuk Murabahah.................................................................................. 4

5.0 Comparison of Sukuk Murabaha with Conventional Bonds...............................................6

Sukuk Islamic vs Conventional Bonds...................................................................................... 6

Risks and Challenges of Sukuk and Conventional Bonds......................................................... 7

6.0 Structure of Sukuk Murabaha in Malaysia...........................................................................9

7.0 Shariah Issues in Sukuk Structures......................................................................................11

Innovative Solutions for Enhancing Sukuk’s Global Integration............................................ 12

8.0 Conclusion.............................................................................................................................. 13

References..................................................................................................................................... 14

​ 1
1.0 Introduction

The global sukuk market has witnessed a significant rise in the issuance of sukuk with a
total of USD 179 billion leading to a 64.4 percent rise in the worldwide market by the end of
second quarter of 2011 and Malaysia is the pioneer of this historical moment in Islamic Finance
industry.1 With this successful event, this paper intended to explore types of sukuk applied in the
global islamic financial market as these Islamic bonds have become an attractive financial tool
for companies and organizations wishing to fund their projects in a legitimate and stable manner
in the dual banking system in Malaysia. This qualitative study adopts documentation and
observation methods by referencing the Shariah rulings, academic articles and standard
regulations by renowned institutions. This discussion encompassed the general concept and
principle of Sukuk, types of Sukuk , what categorises sukuk murabaha falls, how sukuk
murabaha works, the shariah rulings on sukuk Murabaha from authentic sources such as fatwa
and standard regulation by the Security Commission Malaysia (SC) and Accounting and
Auditing Organization for Islamic Financial Institutions (AAOIFI).

2.0 Overview of Sukuk Murabahah

​ Linguistically, the term Murabaha (ٌ‫ ) ُم َرابَ َحة‬refers to achieving profit. It is derived from
the root word ribaḥ which means gain or profit. In Islamic legal terminology, murābaḥah is a
type of trust-based sale in which the seller discloses the original cost of the item to the buyer and
adds a clearly agreed profit margin. It is essentially the resale of something the seller owns
through a prior contract, sold at the original purchase price plus a known profit. According to the
Mālikī school, murābaḥah involves the seller informing the buyer of how much they paid for the
item and then requesting a profit either in a lump sum “I bought this for ten dinars and you profit
me one or two” or by percentage “You profit me one dirham per ten dinars”.2 In the context of
Sukuk Murābaḥah, this concept is applied where investors contribute capital to purchase an
asset. The asset is then sold to a buyer on a deferred payment basis with a disclosed markup. The
profit from the sale is later distributed to sukuk holders as returns. This structure must meet key

1
Norlela Kamaluddin et al., "Shariah Principles of Sukuk Structure in Islamic Capital Market," Journal of
Contemporary Islamic Studies 1 (2015): 64,
https://jcis.uitm.edu.my/journal/volume1/5.%20Shariah%20Principles%20of%20Sukuk%20Structure%20in%20Isla
mic%20Capital%20Market.pdf.
2
Ibn Qudāmah, al-Mughnī, vol. 4, masʾalah 3049.

​ 2
Islamic finance principles, including transparency in cost and profit, freedom from uncertainty
(gharar), and the prohibition of interest (ribā)3. Sukuk Murabahah is an Islamic financial
instrument based on a sale contract, where the seller clearly states the original cost and the profit
margin. It is used to raise funds to finance assets or projects without involving profit-and-loss
sharing. The main goal of Sukuk Murabahah is to provide a Shariah-compliant way for issuers to
get financing, while giving investors a fixed return. In Islamic finance, this type of sukuk
supports the growth of the Islamic capital market by offering investments backed by real assets
and free from interest4

3.0 Types of Sukuk

​ Primarily, Sukuk is categorised according to the contract on which its structure is based.
There are two types of sukuks known as plain sukuk and composite sukuk. Plain sukuk is
defined as sukuk in which the relationship between the Certificateholders and the Originator is
based on a single contract, on the basis of which periodic distributions are paid. There are three
types of plain sukuk accordingly, commutative contracts sukuks or Mu’awadat sukuk,
Musharaka (Partnerships) Sukuks, and Wakala (Agency) Sukuks. Next, a composite sukuks can
be defined as sukuk in which the relationship is established between the Certificateholders and
the Originator on more than one contract in which the subject of each contract differs from the
other. This type of Sukuk is issued through one base prospectus and periodic distributions are
paid on the basis of those contracts. Examples of the composite sukuk are the composite sukuk
of Murabaha and Mudaraba, and investment agency and Ijarah. Sukuk Murabaha could be
categorised under the heading of commutative contracts Sukuks or Mu’awadat Sukuk. This type
of sukuk means the Sukuk in which the relationship between the Certificateholders and the
Originator is based on the one of the commutative contracts for instance, murabaha, ijarah,
istisna’ or others.5

There are four key players in the issuance of Sukuk. The first party is the Originator, an
entity seeking financing and the beneficiary from the proceeds of Sukuk. Following number two

3
Al-Mawsūʿah al-Fiqhiyyah al-Kuwaitiyyah, vol. 37, s.v. “al-Murābaḥah”
4
Dzubaidah Bt. Zainal Abidin and S. Shahida, “Sukuk ‘Asset-Based’ Berbanding Sukuk ‘Asset-Backed’: Kes
Kemungkiran Sukuk,” Prosiding Persidangan Kebangsaan Ekonomi Malaysia ke VIII, Jilid 2 (2013): 576.
5
Accounting and Auditing Organization for Islamic Financial Institutions, Exposure Draft of Shari’ah Standard No.
(62): Sukuk (Bahrain:AAOIFI, 2023), 38, AAOIFI SS 62 ArbEng.

​ 3
is the Issuer, the entity that undertakes the process of offering Sukuks for subscription and it is
often a Special Purpose Vehicle (SPV), and it may be the originator itself. The third key player is
the Trustee which is the party representing the certificateholders and frequently it is a Special
Purpose Vehicle (SPV). The fourth key player is the Sukuk Certificateholders who are among the
investors in the Sukuk, whether they subscribe to the certificates upon issuance or purchase them
from the secondary market.6

4.0 Shariah rulings on Sukuk Murabahah

Sukuk Murabahah is guided by Shariah principles based on the Qur’an, Sunnah, and
scholarly consensus (ijma’). The Qur’an states, “Allah has permitted trade and forbidden
interest” (al-Baqarah 2:275), and “Unless it is a trade conducted with mutual consent” (al-Nisa’
4:29)7, which together form the basis for allowing transactions like Murabahah that are rooted in
mutual agreement and transparency. Scholars from all major Islamic schools agree that
Murabahah is permissible, as it meets the general criteria for a valid sale under Islamic law.
Classical jurists further argued that this type of sale fulfills a social need particularly for
individuals who lack trading experience and wish to rely on the judgment of knowledgeable
sellers8. These individuals are willing to accept the purchase at the seller’s original cost plus a
known profit, as long as the terms are fair and disclosed. Therefore, the general permissibility of
sales in Islam, when conducted under clear and ethical conditions, also applies specifically to
Murabahah.9

The four Sunni schools of thought generally agree on the permissibility of Murabahah,
provided its conditions are fulfilled. The Ḥanafī and Shāfiʿī schools permit it so long as the cost
and profit are clearly disclosed and the contract avoids ambiguity (jahālah). The Mālikī school
also allows it, though it prefers musāwamah (bargaining sale) due to the complexity and potential
risks in ensuring accurate cost disclosure; thus, it is seen as less preferable rather than
invalid10.The Ḥanbalī school permits Murabahah outright if the principal and profit are known,
but reports also exist of dislike (karāhah) from some early scholars due to concerns over

6
Ibid, 5.
7
Al-Qur’an, Surah al-Baqarah 2:275; Surah al-Nisa’ 4:29.
8
Ibid, 2.
9
Ibid, 3.
10
Ibid, 8.

​ 4
uncertainty. In all schools, if the seller falsely reports the cost price, the excess must be deducted
from the profit. These classical views support the foundational structure of Sukuk Murabahah
today, where transparency, risk-bearing, and valid ownership remain key Shariah requirements.11

In Sukuk Murabahah, Shariah rules require that the asset must be halal, owned by the
seller before resale, and the risk must be borne during ownership. The profit must be known and
accepted by both parties. Different Islamic schools of thought accept Murabahah with minor
differences, but all stress honesty and clarity. Modern standards, like those by AAOIFI, allow
trading Murabahah sukuk only if the sukuk represents real assets not just debt. The Islamic Fiqh
Academy also supports its use when the basic rules are followed, such as full disclosure and no
hidden interest.

According to the AAOIFI Shariah Standard No. 17, Sukuk Murabahah may only be
traded when they represent ownership of tangible assets that have been purchased but not yet
sold. This is because such Sukuk are backed by real assets, making them Shariah-compliant and
tradable. However, once the Murabahah commodity has been sold and delivered to the buyer, the
Sukuk effectively represents a debt obligation, and trading in them becomes impermissible
except under strict rules of debt trading. The underlying principle is to avoid interest (ribā) and
ensure that the Sukuk are not merely debt instruments, but instead reflect genuine asset
ownership and risk sharing in line with Islamic finance objectives.

The International Islamic Fiqh Academy echoes this position, emphasizing that
Murabahah contracts must fulfill conditions such as true asset ownership, full price transparency,
and the absence of hidden interest. These rulings help ensure that Sukuk Murabahah remain
within the ethical and legal framework of Shariah by linking investments to real economic
activity and preventing speculative debt-based trading.

11
Ibid, 9.

​ 5
5.0 Comparison of Sukuk Murabaha with Conventional Bonds

Sukuk Islamic vs Conventional Bonds

​ Conventional bonds refer to long-term debt instruments typically issued by corporations

or governments. They provide investors with two main types of returns: (a) the face value, which
is the predetermined sum repaid to bondholders upon maturity; and (b) the coupon payment,
which represents fixed periodic interest paid annually or semi-annually. These payments are
made regardless of whether the issuer earns a profit or suffers a loss from the funds raised
through the bond issuance. Meanwhile, according to the Accounting and Auditing Organization
for Islamic Financial Institutions (AAOIFI), sukuk are equal-value certificates that signify shared
ownership in tangible assets or a portfolio of various assets. These certificates entitle holders to a
portion of the current or future cash flows generated by the assets over a defined period. The
associated risks and returns from these assets are transferred to the sukuk holders. 12

ASPECT SUKUK (ISLAMIC BONDS) CONVENTIONAL BONDS

Legal Claim Represents ownership in assets and Represents a debt obligation

rights to related cash flows. owed by the issuer to the
bondholder.

Return Source Returns are linked to performance of Returns are pre-determined

underlying assets. interest payments (riba).

Income Provides periodic income, similar to Pays fixed interest periodically.

Distribution bonds.

Capital Possible capital gain if asset value No capital gain; principal

Appreciation increases at end of contract. amount is fixed and returned at
maturity.

12
Compare and Contrast Sukuk (Islamic Bonds) with Conventional Bonds: Are They Compatible?, ISFIN, accessed
May 25, 2025,
https://www.isfin.net/sites/isfin.com/files/compare_and_contrast_sukuk_islamic_bonds_with_conventional_bonds_a
re_they_compatible.pdf.

​ 6
 Return Returns are not guaranteed; depend on Returns are guaranteed and
Guarantee asset performance. must be paid by the issuer.

Contractual Based on sale-purchase relationship. Based on the borrower-lender

Nature relationship.

Type of Assets May involve tangible or intangible Usually tied to financial assets
assets, usufructs, or services, existing or or cash flow obligations.
to be delivered.

Rate of Return Can be fixed or variable, depending on Typically offers a fixed rate of
asset performance. return.

Risks and Challenges of Sukuk and Conventional Bonds

Many investors today question the attractiveness of government bonds from developed
countries, especially given that their prices have increased substantially, resulting in historically
low yields. Interest rates in these markets are near record lows and are expected to stay low for a
prolonged period as borrowing by governments, corporations, and households remains
restrained, which may limit economic growth. This environment encourages investors to seek
diversification beyond developed markets to find better yield opportunities.

Generally, conventional bonds are exposed to several financial risks that can affect their
value and attractiveness to investors. The first risk is named as Call Risk, which occurs when
issuers redeem bonds before maturity, typically when market interest rates fall. As a result,
investors lose the benefit of the higher interest rates originally promised. This risk does not
generally apply to sukuk, as they are structured differently and are not directly tied to interest
rate fluctuations. Next is Interest Rate Risk (Return Risk). A significant source of price
instability in the bond market is interest rate risk. Since conventional bonds offer fixed returns,
their prices typically move inversely with market interest rates. An increase in interest rates leads
to a drop in bond prices and vice versa. Moreover, changing rates affect reinvestment returns
from interest payments. Bonds with longer maturities are more susceptible to this risk due to
their extended exposure to potential rate changes. Properly managing bond duration can help

​ 7
mitigate this risk. Other than that, conventional bonds are also exposed to Downgrade Risk,
where the Bondholders genuinely face the risk of a decline in bond value due to a downgrade in
the issuer’s credit rating by agencies. A downgrade suggests higher default risk, lowering the
bond's price in the secondary market and negatively impacting investors aiming to resell.

Sukuk, which comply with Islamic law, provide medium- to long-term returns that may
be fixed or variable. When compared to conventional global bonds, sukuk generally offer
superior risk-adjusted returns. Unlike bonds from emerging markets, which often deliver high
returns accompanied by high volatility, sukuk performance tends to be steadier with relatively
lower volatility. One such risk is price risk, also referred to as asset redemption risk. Since sukuk
must be backed by tangible assets, there is a possibility that the value of these assets may
depreciate significantly by the time they are repurchased by the originator at maturity. Factors
such as wear and tear, overuse, or damage could result in the final repayment amount being
lower than the initial investment, exposing investors to losses. Another key concern is Shariah
compliance risk, which arises if the sukuk fails to fully adhere to Islamic principles. This can
happen if the Shariah board only reviews the structure at the issuance stage and does not oversee
the instrument throughout its lifecycle. Non-compliance may harm the issuer’s credibility and
discourage future investor participation. Furthermore, sukuk are also subject to operational risk,
particularly because their returns are derived from physical assets. Any disruption or delay in the
performance or utilization of these assets can affect the income stream to investors. This risk is
unique to sukuk and not present in conventional bonds, which are not linked to specific asset
performance. Lastly, sukuk face legal and regulatory risks due to the lack of standardization
across jurisdictions. Conflicts may arise between Shariah requirements and the regulatory
frameworks of different countries. While organizations like AAOIFI and IFSB are working
toward harmonization, inconsistencies in governance still pose a challenge to the development of
a unified global sukuk market.13

From a research study, it analyzed data from a three-year span ending December 2013,
the Dow Jones Sukuk Index outperformed the JP Morgan GBI Broad Index, representing
conventional bonds, while exhibiting less volatility. Moreover, between June 2011 and June

13
A. A. Tariq, Managing Financial Risks of Sukuk Structures (master’s thesis, Loughborough University, 2004),
https://www.iefpedia.com/english/wp-content/uploads/2009/09/MANAGING-FINANCIAL-RISKS-OF-SUKUK-S
TRUCTURES.pdf

​ 8
2013, the global sukuk market surpassed the global bond market, represented by the CITI World
Broad Investment Grade Bond Index, with average annualized returns of 3.71% versus 0.57%.
This demonstrates that sukuk were more than six times as profitable during that period.
Therefore, in terms of risk, sukuk also show an advantage, with a volatility rate of 2.24%, which
is less than half the 4.66% volatility of the WorldBIG bond index. This suggests sukuk provide
investors with a more favorable combination of profitability and lower risk compared to
conventional bonds.14

6.0 Structure of Sukuk Murabaha in Malaysia

Malaysia adopted sukuk murabaha as an alternative structure used to raise capital

expenditure and general working capital requirements.15 Sukuk is divided into three types. The
first type is equity-based Sukuk (EBS) formulated from the contract of Mudarabah and
Musharakah, following the second type is debt-based Sukuk (DBS) originated from the contract
of Qard Hassan, Murabaha, Salam, Istisna’ and Ijarah. The third type is a hybrid Sukuk (HMS)
structured from the combination of the contract of Ijarah, Murabaha and Istisna’. There are three
parties taking part excluding the Trustee, in contrast to the major roles specified by the
AAOIFI.16 This framework begins with the issuance of Sukuk. The financier buys commodities
and then immediately sells those commodities back to the Issuer at a markup price that is
mutually agreed upon. The issuance of Murabaha Notes securities the obligation of the Issuer to
pay the purchase price. Afterwards, the commodities are transferred to a Special Purpose Vehicle
(SPV) who serves as the Issuer by packaging them in securities (Sukuk) to be issued to the
investors. The certificateholders thereafter became the owner of the commodities through
utilising the subscription’s profits to buy the commodities. Following this, the certificate holder
sold the commodities to the Originator on a Murabaha basis. In summary, the certificateholders

14
Abdurahman Jemal Yesuf, “A Comparative Analysis of Sukuk and Conventional Bonds,” Springer International
Publishing Switzerland 2016, accessed May 25, 2025,
https://www.researchgate.net/publication/300335119_A_Comparative_Analysis_of_Sukuk_and_Conventional_Bon
ds.
15
MARC Ratings Berhad, Rating Approach to Sukuk, January 2022: 9,
https://www.marc.com.my/wp-content/uploads/2023/Rating%20Methodologies/Sukuk%20Rating%20Approach%20
202201.pdf.
16
Norlela Kamaluddin et al., "Shariah Principles of Sukuk Structure in Islamic Capital Market," Journal of
Contemporary Islamic Studies 1 (2015): 69,
https://jcis.uitm.edu.my/journal/volume1/5.%20Shariah%20Principles%20of%20Sukuk%20Structure%20in%20Isla
mic%20Capital%20Market.pdf.

​ 9
at first become the buyer of the commodities and then as a seller of the commodities. The
certificateholders retain the ownership of the commodities after its purchase and before the
Murabaha contract takes place. Also, the certificateholders are entitled to receive the proceeds
from the sale of the underlying assets.

An example of Sukuk Murabaha is TTM Sukuk Berhad (TTM SPV). This is an equal
joint venture of Malaysia’s national oil company Petroliam Nasional Berhad (Petronas) and
Thailand’s PTT Public Company Ltd (PTT). This project consists of a gas pipeline and a gas
separation plant (GSP) to transport and process natural gas from the gas reserves in the
Thai-Malaysia Joint Development Area to southern Thailand and on to Kedah. The TTM Project
Phase 2 has been fully operational since June 2010. The sukuk issued in November the same
year and matures in 2024.

TTM SPV was formed as a fundraising vehicle for the issuance of RM600 million sukuk
murabahah. TTM SPV was appointed as the certificateholders' purchasing agent for the purchase
and sale of Shariah-compliant commodities. The revenues are utilized to cover the purchase price
of the commodities. In the hat of a purchaser, TTM SPV then purchased the commodities from
the certificateholders at a deferred sale price and sold them on the spot basis. During the process,
the purchase and onward selling of the commodities occurred on the same day. The revenues
from the commodity sales were loaned to TTM SPV's parent company, Trans Thai-Malaysia
(Thailand) Ltd (TTMT). The payment received was utilised to fund the capital expenses and
working capital requirements. The Sukuk's repayment comes from TTMT repaying the
intercompany loan structured to match the sukuk's maturity profile. Sukuk transaction was
considered as a project financing due to TTMT’s debt service capacity being derived from cash
flows generated by underlying projects assets and contracts.17

​ In addition, Bank Islam Malaysia Berhad has issued RM1.0 billion Senior Sukuk
Murabahah in July 2024 under its RM10.0 billion Sukuk Murabahah Programme. The Bank
serves as the Principal Advisor, Lead Arranger/ SPV, Lead Manager/the Originator/ the Issuer
and Shariah Advisor for the said programme. With the purposes to finance its banking activities,

17
MARC Ratings Berhad, Rating Approach to Sukuk, January 2022: 11,
https://www.marc.com.my/wp-content/uploads/2023/Rating%20Methodologies/Sukuk%20Rating%20Approach%20
202201.pdf.

​ 10
working capital requirements and other corporate matters. To attract potential investors, this
sukuk has been rated AA3/stable with offers of fixed profits ranging from 4.01% and 4.13% per
annum by RAM Holdings Berhad.18

7.0 Shariah Issues in Sukuk Structures

While sukuk are generally regarded as Shariah-compliant alternatives to conventional

bonds, their growing complexity and commercial innovation have prompted various Shariah
scholars to scrutinize whether modern sukuk structures truly uphold Islamic legal and ethical
principles. Although sukuk are structured to adhere to Islamic principles, several Shariah-related
concerns have been raised by scholars.

As discussed by the Shariah Committee of the Maybank Malaysia Group, one key issue
is the question of beneficial ownership, where sukuk holders may not truly own the underlying
assets, but merely have a claim on cash flows generated by them. This undermines the concept of
milkiyyah tammah (complete ownership), which is essential in Islamic contracts. Another major
concern involves the purchase undertaking, often embedded in sukuk structures, where the
originator promises to repurchase the asset at a fixed price upon maturity. This pre-agreed price
does not necessarily reflect the market value, raising concerns of it being a disguised
interest-based transaction. Moreover, in certain equity-based sukuk structures like Musharakah
and Mudarabah, practices such as tanazul (waiver of profit rights) are employed to ensure a
predictable return for some investors, which goes against the profit-and-loss sharing nature of
such contracts. There are also concerns regarding the rebate mechanism (ibra’) provided in early
settlement cases, which, if predetermined, could replicate conventional interest. The use of
liquidity facilities in sukuk, although essential for financial stability, may involve loans that
resemble interest-bearing transactions if not carefully structured. Furthermore, the tradability of
debt-based sukuk such Sukuk Murabahah remains controversial, as trading such instruments
above par is generally not permissible under Shariah. Lastly, when sukuk are backed by a pool of
mixed assets, including non-Shariah-compliant elements, the presence of even a small proportion
of impermissible components raises questions about the overall legitimacy of the sukuk. These
issues highlight the complexity of ensuring full Shariah compliance in modern sukuk offerings

18
Bank Islam Malaysia Berhad, Bank Islam Issues RM1.0 billion senior sukuk murabahah, July 2024, 15.
MEDIA-RELEASE-BANK-ISLAM-ISSUES-RM1.0-BILLION-SENIOR-SUKUK-MURABAHAH.pdf

​ 11
and emphasize the importance of continuous oversight by Shariah advisory boards throughout
the sukuk’s life cycle.19

Innovative Solutions for Enhancing Sukuk’s Global Integration

​ A study has found several innovative sukuk structures that have emerged to meet the
evolving needs of investors and to align with global financial trends, to make sukuk more
appealing and feasible in global markets. One of them is Green Sukuk, which is issued to fund
environmentally sustainable projects such as renewable energy, green buildings, or clean
transportation. It combines Islamic finance principles with environmental responsibility. This
innovation aims to align with global efforts to tackle climate change, allowing environmentally
conscious investors to participate in Islamic capital markets. Other than that, this article suggests
Socially Responsible Investment (SRI) Sukuk, which are designed to attract investors looking for
ethical investments. These sukuk focus on funding projects that have a positive social impact,
such as education, healthcare, and infrastructure. They incorporate Environmental, Social, and
Governance (ESG) criteria and are often structured to meet global sustainability standards,
enhancing their international appeal. Lastly, Wakalah Sukuk which is based on an agency
agreement, where investors appoint an agent (wakeel) to invest on their behalf. This structure
provides flexibility in asset management and is suitable for various types of underlying assets. It
is often used to streamline complex sukuk structures and improve transparency and
risk-sharing.20

All in all, the ongoing innovations in sukuk structures such as Green Sukuk, SRI Sukuk,
and Wakalah Sukuk demonstrate the flexibility and adaptability of Islamic finance in meeting
global demands. The expansion in its application may promote global integration of Sukuk at a
high level of markets. These advancements not only uphold Shariah principles but also align
with modern investment goals, including sustainability and ethical impact. By embracing such
innovations, sukuk can strengthen their role in the international financial system and offer a

19
Shariah Committee of Maybank Islamic Berhad, Shariah Issues in Sukuk (Kuala Lumpur: Maybank Islamic
Berhad, 2014),
https://www.maybank2u.com.my/iwov-resources/islamic-my/document/my/en/islamic/scoe/knowledge-centre/resear
ch-paper/Shariah_%20Issues_in_Sukuk.pdf.
20
Nor Razinah Mohd Zain, Adewale Abideen, and Engku Rabiah Adawiah Engku Ali, "Innovations in Sukuk in the
Global Finance Market: Reviewing Key Considerations," International Journal of Management and Applied
Research 6, no. 4 (2019): 285–295, https://www.ijmar.org/v6n4/19-021.html.

​ 12
competitive alternative to conventional instruments, ultimately contributing to the growth of a
more inclusive and responsible global financial market.

8.0 Conclusion

Sukuk Murabahah is now an important part of Islamic finance because it gives a

Shariah-compliant and ethical choice for companies to raise money without using interest. It
works through a sale contract where the seller tells the buyer the actual cost and agreed profit,
making the process clear and fair. This structure allows investors to get steady returns while
following Islamic rules. Still, there are a few issues. Some Sukukholders may not really own the
assets, which goes against Shariah principles. Also, once the asset is sold, the Sukuk becomes a
debt, which makes it hard to trade under Islamic law. There are also risks if the Sukuk does not
continue to follow Shariah rules properly over time, and different countries have different
regulations, which can create confusion. To fix this, new Sukuk models like Green Sukuk, SRI
Sukuk, and Wakalah Sukuk have been introduced. These not only follow Islamic rules but also
support global goals like environmental care and social responsibility. Even with these
improvements, Sukuk structures must still be reviewed and improved regularly to stay within
Shariah guidelines. Future research should look into better global standards, clearer structures,
and more real-asset involvement so that Sukuk Murabahah can continue to grow and compete in
the global financial market.

​ 13
 References

Abdurahman Jemal Yesuf, “A Comparative Analysis of Sukuk and Conventional Bonds,”

Springer International Publishing Switzerland 2016, accessed May 25, 2025,
https://www.researchgate.net/publication/300335119_A_Comparative_Analysis_of_Suku
k_and_Conventional_Bonds.

Al-Mawsūʿah al-Fiqhiyyah al-Kuwaitiyyah, vol. 37, s.v. “al-Murābaḥah.” Kuwait: Wizārat

al-Awqāf wa al-Shuʾūn al-Islāmiyyah, 1998.

BANK ISLAM ISSUES RM1.0 BILLION SENIOR SUKUK MURABAHAH. (n.d.). Bank Islam
Malaysia Berhad. July 15, 2024.
https://www.bankislam.com/wp-content/uploads/MEDIA-RELEASE-BANK-ISLAM-IS
SUES-RM1.0-BILLION-SENIOR-SUKUK-MURABAHAH.pdf

“Exposure Draft of Shari’ah Standard No. (62): Sukuk.” 2023. AAOIFI. Accounting and
Auditing Organization for Islamic Financial Institutions. November 6, 2023.
https://aaoifi.com/wp-content/uploads/2023/11/DRAFT-AAOIFI-SS-62-ArEn.pdf

ISFIN. Compare and Contrast Sukuk (Islamic Bonds) with Conventional Bonds: Are They
Compatible? Accessed May 25, 2025.
https://www.isfin.net/sites/isfin.com/files/compare_and_contrast_sukuk_islamic_bonds_
with_conventional_bonds_are_they_compatible.pdf.

Ibn Qudāmah. al-Mughnī, vol. 4, masʾalah 3049. Cairo: Maktabat al-Qāhirah, n.d.

Kamaluddin, Norlela, Siti Khadijah Ab. Manan, Fadzlan Sufian, and Shila Nu Nu Htay. "Shariah
Principles of Sukuk Structure in Islamic Capital Market." Journal of Contemporary
Islamic Studies 1 (2015): 63–76.
https://jcis.uitm.edu.my/journal/volume1/5.%20Shariah%20Principles%20of%20Sukuk%
20Structure%20in%20Islamic%20Capital%20Market.pdf

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MARC Ratings Berhad. 2022. “RATING METHODOLOGY RATING APPROACH to SUKUK
CROSS-SECTOR.”
https://www.marc.com.my/wp-content/uploads/2023/Rating%20Methodologies/Sukuk%
20Rating%20Approach%20202201.pdf.

Nor Razinah Mohd Zain, Adewale Abideen, and Engku Rabiah Adawiah Engku Ali,
"Innovations in Sukuk in the Global Finance Market: Reviewing Key Considerations,"
International Journal of Management and Applied Research 6, no. 4 (2019): 285–295,
https://www.ijmar.org/v6n4/19-021.html.

Shariah Committee of Maybank Islamic Berhad. Shariah Issues in Sukuk. Kuala Lumpur:
Maybank Islamic Berhad, 2014.
https://www.maybank2u.com.my/iwov-resources/islamic-my/document/my/en/islamic/sc
oe/knowledge-centre/research-paper/Shariah_%20Issues_in_Sukuk.pdf.

Tariq, A. A. Managing Financial Risks of Sukuk Structures. Master’s thesis, Loughborough

University, 2004,
https://www.iefpedia.com/english/wp-content/uploads/2009/09/MANAGING-FINANCI
AL-RISKS-OF-SUKUK-STRUCTURES.pdf

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