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Islamic Contract – Bay’ al-Istijrār (Supply or Wholesale Sale)
1. Definition of Bay’ al-Istijrār
Literal Meaning
The word istijrār is derived from the Arabic verb:
istajarra
which means:
  • to pull;
  • to drag;
  • to draw along.
It may also carry the meaning of:
deferral,
particularly in relation to deferred debt or payment.


2. Technical Definition of Bay’ al-Istijrār
Technically, Bay’ al-Istijrār (hereinafter, istijrār) refers to:
a sale arrangement in which the buyer continuously takes merchandise from the seller in instalments or on a regular basis, while payment may be made either later or in advance.


Earlier Definition
Some jurists earlier defined istijrār as:
taking goods continuously from a vendor and paying later.
This definition focused mainly on:
  • deferred payment arrangements.


More Accurate Definition
However, some scholars argue:
this definition is incomplete,
because:
  • payment in istijrār may be:
    • deferred; or
    • upfront.
Thus:
  • the concept is broader than merely deferred payment.


Definition by al-Ashqar
Al-Ashqar defines istijrār as:
taking merchandise from the vendor in instalments on a regular basis while payment may be made in advance or deferred.


Definition by Securities Commission Malaysia
The Securities Commission Malaysia defines istijrār as:
“a contract whereby the supplier agrees to supply a particular product on an ongoing basis, e.g., monthly, at an agreed price and an agreed mode of payment.”


Main Features of Istijrār
1. Continuous Supply Relationship
Goods are supplied:
  • continuously;
  • periodically;
  • regularly.
Examples:
  • daily;
  • weekly;
  • monthly.


2. Goods Taken in Stages
The buyer:
  • does not necessarily take all goods at once.
Instead:
  • goods are withdrawn progressively.


3. Payment Flexibility
Payment may be:
✅ upfront;
✅ deferred;
✅ periodic;
✅ instalment-based.


4. Common in Commercial Supply Chains
Istijrār is commonly used in:
  • wholesale trade;
  • supermarkets;
  • restaurants;
  • manufacturing supply chains;
  • trade finance.


Example 1 – Istijrār With Deferred Payment
A restaurant regularly purchases:
  • chicken supplies from wholesaler.


Supply Arrangement
Week 1
100 kg chicken
Week 2
120 kg chicken
Week 3
90 kg chicken
The restaurant:
  • takes goods continuously;
  • pays supplier at month-end.


Analysis
The goods are:
  • supplied regularly;
  • taken in stages;
  • paid later.
Result
✅ Istijrār with deferred payment.


Example 2 – Istijrār With Upfront Payment
A factory prepays:
  • RM500,000
    to steel supplier.
The supplier then:
  • delivers steel monthly over one year.


Analysis
Payment:
✅ made upfront.
Goods:
✅ supplied gradually.
Result
✅ Istijrār with upfront payment.


Example 3 – Modern Commercial Example
A supermarket signs agreement with beverage company.
The beverage company agrees:
  • to supply drinks weekly.
The supermarket agrees:
  • to pay every 30 days.


Features Present
✅ continuous supply
✅ repeated withdrawals
✅ agreed payment mechanism
Result
✅ Contemporary istijrār arrangement.


Importance of Istijrār in Islamic Finance
Istijrār is important because:
  • modern businesses require continuous supply arrangements;
  • repeated contracting for every transaction may be impractical;
  • it facilitates trade and commercial efficiency.


Application in Islamic Finance
Istijrār may be used in:
  • Islamic trade finance;
  • import financing;
  • wholesale supply arrangements;
  • Islamic letter of credit facilities.
It serves as:
an alternative to murābahah or tawarruq-based trade financing.


Sharī‘ah Issues in Istijrār
The major Sharī‘ah issues concern:
  • certainty of price;
  • contractual formation;
  • deferred payment;
  • ownership and possession;
  • uncertainty (gharar).
Jurists therefore differ regarding:
  • pricing methods;
  • sale by conduct (bay‘ al-mu‘āṭāh);
  • unknown pricing structures.


Important Sharī‘ah Principle
Istijrār is generally permissible because:
the original rule in commercial transactions is permissibility,
provided:
✅ mutual consent exists;
✅ contractual obligations are clear;
✅ excessive uncertainty is avoided;
✅ Sharī‘ah requirements of sale are fulfilled.

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Islamic Contract – Legality of Bay’ al-Istijrār
1. General Legality of Istijrār
Explanation
In general:
Muslim jurists agree on the permissibility of istijrār,
based on:
  • the general permissibility of sale contracts in Islamic law.
This permissibility applies particularly when:
✅ the price is known to both contracting parties.


What Is Istijrār?
Istijrār refers to:
a continuous supply arrangement where a buyer repeatedly takes goods from a seller over time with periodic settlement of payment.
It is commonly used in:
  • wholesale supply;
  • retail supply;
  • trade financing;
  • import-export transactions.


Example of Permissible Istijrār
A restaurant regularly purchases:
  • rice from supplier.
Every week:
  • quantity and price are specified.
At month-end:
  • payment is settled collectively.


Example With Figures
Week 1
50 bags rice at RM80 each
50 \times 80 = 4{,}000
50 \times 80 = 4{,}000


Week 2
60 bags rice at RM82 each
60 \times 82 = 4{,}920
60 \times 82 = 4{,}920


Total Month-End Payment
4{,}000 + 4{,}920 = 8{,}920
4{,}000 + 4{,}920 = 8{,}920


Result
✅ Permissible because:
  • goods known;
  • prices known;
  • obligations clear.


2. Position of the Shāfi‘ī School
Majority Shāfi‘ī View
The majority of the Shāfi‘ī School:
❌ do not generally recognise:
sale by conduct (bay‘ al-mu‘āṭāh)
without:
  • explicit offer (ijāb);
  • explicit acceptance (qabūl).


What Does This Mean?
According to the majority Shāfi‘īs:
  • every sale transaction should contain:
    • expressed offer;
    • expressed acceptance.
Thus:
  • merely taking goods and paying later without verbal/formal contract may be insufficient.


Example
A customer enters grocery shop:
  • takes bread daily;
  • no formal agreement;
  • pays at month-end.


Majority Shāfi‘ī Concern
Because:
  • no explicit sale contract formed each time,
    they may regard:
    ❌ the transaction as problematic.


Some Shāfi‘ī Scholars Were More Flexible
Certain Shāfi‘ī scholars such as:
  • al-Ghazālī;
  • Ibn Surayj
were more accepting of:
sale by conduct (bay‘ al-mu‘āṭāh).
Especially where:
  • customary practice clearly indicates mutual consent.


3. Position of the Mālikī School
Mālikī View
The Mālikī School generally:
✅ allows istijrār.
However:
  • the contract begins:
once the buyer takes the commodity from seller.
Thus:
  • taking possession itself signifies contractual consent.


Example
A bakery regularly takes:
  • flour supplies from wholesaler.
The bakery:
  • simply collects flour;
  • records quantities;
  • pays later.


Mālikī Analysis
The act of:
  • taking the flour
itself constitutes:
✅ contractual formation.


4. Unknown Price Issue in Istijrār
Main Sharī‘ah Concern
Jurists differ regarding:
permissibility of istijrār when the price is unknown at the time goods are taken.


Why Is This Important?
Islamic commercial law generally requires:
✅ certainty of price (thaman).
Uncertainty regarding price may create:
❌ gharar (excessive uncertainty).


Example of Problematic Situation
A retailer continuously takes:
  • beverages from supplier.
No:
  • exact price;
  • pricing formula;
  • market benchmark
is agreed upon initially.
Only later:
  • parties negotiate total amount.


Juristic Concern
At the time goods are taken:
❌ price remains uncertain.
This may lead to:
  • disputes;
  • unfairness;
  • unlawful consumption of wealth.


Majority Position
Most jurists:
❌ do not allow sales with unknown prices.
They rely on:
  • Qur’ānic prohibition against unlawful appropriation of wealth;
  • prohibition of gharar;
  • requirement of certainty in contracts.


Minority Position
Some Hanafi and Hanbali jurists:
✅ allow reliance on:
  • prevailing market price;
  • commercial custom (‘urf);
  • public need.
Especially where:
  • market prices are stable and commonly known.


Example of Permissible Market-Based Practice
A petrol station continuously receives:
  • fuel supply.
Daily market price:
  • publicly displayed;
  • commercially standardised.
Thus:
  • some jurists tolerate deferred reconciliation using prevailing market rates.


5. Important Sharī‘ah Principles in Istijrār
Principle 1
Sale Contracts Are Generally Permissible
Based on:
  • general permissibility of trade in Islam.


Principle 2
Mutual Consent Is Required
Contracting parties must genuinely consent.


Principle 3
Price Certainty Is Important
Islamic law generally requires:
✅ known price;
✅ known obligations.


Principle 4
Excessive Uncertainty (
Gharar
) Must Be Avoided
Unknown prices may invalidate sales.


Principle 5
Commercial Custom (
‘Urf
) May Be Considered
Some jurists allow flexibility where:
  • stable market practices exist;
  • public need is widespread.


Overall Conclusion
Istijrār is generally:
✅ permissible in Islamic law,
particularly when:
  • goods are known;
  • prices are known;
  • contractual obligations are clear.
However:
  • jurists differ regarding:
    • sale by conduct (bay‘ al-mu‘āṭāh);
    • unknown pricing;
    • deferred settlement structures.
The major Sharī‘ah concern remains:
avoiding uncertainty and ensuring fairness in commercial transactions.

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Islamic Contract – Bay’ al-Istijrār: Istijrār With Deferred Payment
1. Definition of Istijrār With Deferred Payment
Explanation
Istijrār with deferred payment refers to:
a continuous supply arrangement where the buyer takes goods gradually over time and payment is deferred until a later date or settlement period.
Instead of:
  • paying immediately upon each withdrawal,
the buyer:
  • receives goods continuously;
  • settles payment later.
Scholars differ regarding:
  • the permissibility of various forms of this arrangement,
    particularly:
  • price determination.


2. Types of Istijrār With Deferred Payment
Scholars discuss several forms of deferred-payment istijrār.


A. Price Specified in Every Transaction
Structure
In this form:
  • every time goods are taken,
  • the price is clearly specified.
Although payment is deferred,
the parties know:
✅ exact quantity
✅ exact price
during each transaction.


Scholarly View
This form is generally:
✅ permissible.
It is accepted by scholars who allow:
sale by conduct (bay‘ al-mu‘āṭāh).


Schools Allowing It
✅ Hanafis
✅ Mālikis
✅ Hanbalis
✅ Some Shāfi‘ī scholars
(such as al-Ghazālī and Ibn Surayj)


Majority Shāfi‘ī Position
The majority of Shāfi‘ī jurists:
❌ do not allow it.


Example
A restaurant regularly purchases:
  • chicken supplies from wholesaler.


Week 1
  • 100 kg chicken
  • RM15 per kg
Price
100 \times 15 = 1{,}500
100 \times 15 = 1{,}500


Week 2
  • 120 kg chicken
  • RM16 per kg
Price
120 \times 16 = 1{,}920
120 \times 16 = 1{,}920


End of Month
Restaurant pays:
1{,}500 + 1{,}920 = 3{,}420
1{,}500 + 1{,}920 = 3{,}420


Analysis
Every withdrawal:
  • has known price;
  • has known quantity.
Only payment is deferred.
Result
✅ Generally permissible according to majority non-Shāfi‘ī schools.


B. Price Not Specified Each Time But Determined by Market Price on Day Goods Are Taken
Structure
In this form:
  • goods are taken continuously;
  • price not expressly stated during each withdrawal.
However:
  • parties initially agree that:
price shall follow prevailing market price on the day goods are taken.


Majority Juristic View
The famous opinion among the four schools:
❌ generally does NOT allow this arrangement.
Why?
Because:
  • price is unknown during contract session;
  • uncertainty (gharar) exists.


Basis of Prohibition
The jurists rely upon:
  • Qur’ānic prohibition against unlawful consumption of wealth;
  • prohibition of uncertainty in contracts;
  • scholarly consensus requiring known price.


Example
A supermarket continuously takes:
  • vegetables from supplier.
No exact price stated during each withdrawal.
Parties merely agree:
“Price will follow market price each day.”


Problem
At the moment goods are taken:
❌ exact price unknown.
This may lead to:
  • disputes;
  • uncertainty.
Result
❌ Invalid according to majority view.


Minority Hanafi and Hanbali View
Some Hanafi and Hanbali jurists:
✅ allow this arrangement
if:
  • market price is stable and commonly known.


Basis of Their Opinion
They rely on:
  • customary market practice (‘urf);
  • prevailing market value (thaman al-mithl);
  • practical commercial necessity.


Example
A petrol station regularly takes:
  • fuel supplies.
Daily market price:
  • publicly known and stable.
Thus:
  • parties rely on prevailing market rate.
Result
✅ Permissible according to some Hanafi and Hanbali jurists.


C. Price Not Specified and No Agreed Pricing Mechanism
Structure
In this form:
  • goods are continuously taken;
  • no exact price stated;
  • no agreed pricing formula;
  • final payment determined only during later account reconciliation.


Majority Juristic View
Most jurists:
❌ prohibit this arrangement.
Why?
Because:
  • contract lacks certainty regarding price;
  • excessive gharar exists.


Example
A retailer continuously takes:
  • beverages from supplier.
No:
  • price;
  • pricing formula;
  • market benchmark
is agreed initially.
At month-end:
  • parties negotiate final amount.


Problem
At time goods are taken:
❌ no binding sale price exists.
Thus:
  • contract remains incomplete.
Result
❌ Invalid according to majority.


Later Hanafi Position
Some later Hanafi scholars:
✅ allowed this arrangement
if:
  • parties finally agree on price during reconciliation stage.
They based this on:
  • juristic preference (istihsān);
  • commercial custom (‘urf);
  • widespread public need (‘umūm al-balwā).


Example
A grocery store continuously receives:
  • bread supplies daily.
No exact price fixed initially.
At month-end:
  • parties reconcile account using accepted market rates.
Because this practice:
  • became widespread commercial custom,
later Hanafi scholars:
✅ tolerated it.


3. Comparative Summary
Type A
Price Specified in Every Transaction
Majority View
✅ Permissible.
Reason
Price known at every withdrawal.


Type B
Market Price Used But Not Expressly Stated
Majority View
❌ Not permissible.
Minority Hanafi/Hanbali View
✅ Permissible if market price stable.


Type C
No Price and No Pricing Mechanism Initially
Majority View
❌ Not permissible.
Later Hanafi View
✅ Permissible after reconciliation based on custom.


4. Important Sharī‘ah Principle
The major concern in deferred-payment istijrār is:
uncertainty regarding price (jahālah al-thaman).
Islamic commercial law generally requires:
✅ certainty of price;
✅ certainty of obligations;
✅ avoidance of excessive gharar.
However:
  • some jurists allow flexibility where:
    • strong commercial custom exists;
    • public need is widespread;
    • market prices are stable and commonly known.

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Islamic Contract – Bay’ al-Istijrār: Istijrār With Upfront Payment
1. Definition of Istijrār With Upfront Payment
Explanation
This type of istijrār involves:
the buyer paying money upfront to the seller for a specified quantity of goods that will be supplied gradually in stages over time.
Instead of:
  • immediate full delivery,
the goods are:
  • withdrawn progressively according to need.


Simple Example
A restaurant pays:
  • RM100,000 upfront
    to a food supplier for:
  • monthly supply of chicken over 1 year.
The supplier then:
  • delivers portions gradually every month.
Result
✅ Istijrār with upfront payment.


2. Scholarly Views on Istijrār With Upfront Payment
Majority of Scholars
The majority of scholars:
✅ permit this arrangement,
although they differ regarding:
the fiqh characterization (takyīf fiqhī) of the contract.
Some classify it as:
  • salam-like arrangement;
  • continuous supply sale;
  • hybrid contractual structure.


Shāfi‘ī School
The Shāfi‘ī jurists:
❌ do not permit this form of istijrār.
Why?
Because:
  • payment occurs upfront;
  • goods are delivered gradually later;
  • uncertainty may arise regarding staged delivery.


3. SAC-BNM Approval on Istijrār Trade Financing
SAC-BNM Resolution
The:
Shariah Advisory Council of Bank Negara Malaysia (SAC-BNM)
at its:
194th meeting on 25 June 2019
approved:
a proposed import financing structure based on bay’ al-istijrār.
This approval was specifically for:
  • Islamic trade finance facilities;
  • Islamic letter of credit financing.


4. Structure of Istijrār Import Financing
The structure generally involves:
  • Islamic Financial Institution (IFI);
  • importer/customer;
  • exporter/supplier.


Chronological Flow of Istijrār Import Financing
STEP 1 — Customer Wants to Import Goods
A Malaysian importer wishes to import:
  • industrial machinery from Germany.
Import Value
RM2,000,000
The customer requests:
  • Islamic trade financing facility.


STEP 2 — Customer Appointed as Agent
The Islamic bank appoints:
the importer/customer as purchasing agent (wakīl).
The customer now acts:
  • on behalf of the Islamic bank
    to purchase goods.


SAC-BNM Requirement
The facility agreement must clearly specify:
the importer’s responsibility as purchasing agent.


STEP 3 — Customer Purchases Goods for Bank
As agent:
  • the importer executes purchase transaction with exporter
    on behalf of:
  • Islamic bank.
At this stage:
✅ goods are purchased for the bank,
not yet for customer personally.


STEP 4 — Islamic Bank Becomes Owner of Goods
Once purchase completed:
✅ ownership transfers to Islamic bank.
Thus:
  • the bank bears ownership risk at this stage.


STEP 5 — Exporter Ships Goods
The exporter ships:
  • industrial machinery.
Shipping documents are issued.


STEP 6 — Customer Receives Goods/Documents
The imported goods and/or shipping documents arrive.


STEP 7 — Customer Purchases Goods From Islamic Bank
After agency role completed,
the customer now enters:
separate purchase transaction with the Islamic bank.
This is important because:
  • agency role must finish first;
  • customer cannot simultaneously act as:
    • purchasing agent;
    • purchaser.


SAC-BNM Requirement
The IFI must ensure:
proper sequencing of transactions.
Meaning:
  1. agency purchase first;
  2. customer purchase from bank second.


STEP 8 — Customer Pays Bank
The customer pays:
  • agreed financing price;
  • either deferred or instalment basis.


Example With Figures
Import Cost Paid by Islamic Bank
RM2,000,000
Selling Price to Customer
RM2,300,000


Bank’s Profit
2{,}300{,}000 - 2{,}000{,}000 = 300{,}000
2{,}300{,}000 - 2{,}000{,}000 = 300{,}000


5. Why Proper Sequencing Is Important
Incorrect Structure
If customer:
  • purchases goods before agency role completed,
then:
  • contracts may overlap improperly;
  • ownership transfer becomes unclear;
  • Sharī‘ah issues may arise.


Correct Structure
Sequence Must Be:
  1. Customer acts as agent for bank.
  2. Bank acquires ownership.
  3. Customer later buys goods from bank.


6. Risks and Liabilities
The agreement must clearly determine:
  • who bears ownership risk;
  • liabilities at each stage.


Example
Before Customer Purchases From Bank
✅ Bank bears ownership risk.


After Customer Purchases From Bank
✅ Customer bears ownership risk.


7. Why SAC-BNM Allowed This Structure
SAC-BNM approved this structure because:
  • modern trade finance requires practical import financing solutions;
  • continuous supply financing is commercially needed;
  • the structure facilitates Sharī‘ah-compliant international trade.
However:
the approval is confined specifically to the proposed trade finance structure.


Important Sharī‘ah Principle
Istijrār financing is permissible only if:
✅ proper ownership transfer occurs;
✅ agency and sale contracts are separated;
✅ sequencing is properly maintained;
✅ ownership risks are genuinely borne by the correct party.
Otherwise:
❌ the arrangement may resemble conventional interest-based financing.

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Islamic Contract – Application of Istijrār in Islamic Finance
Q1: What is istijrār?
Answer
Istijrār refers to:
a contractual arrangement where a buyer continuously purchases goods from a seller over a period of time, usually with periodic settlement of payment.
Instead of:
  • concluding a separate contract for every individual purchase,
the parties:
  • establish an ongoing supply arrangement.
Istijrār is commonly suitable for:
  • repetitive supply transactions;
  • trade financing;
  • import-export businesses.


Q2: How is istijrār applied in Islamic finance?
Answer
In contemporary Islamic finance, istijrār can be used to structure:
Islamic trade financing facilities,
particularly:
  • import financing under a letter of credit (LC).
Under this arrangement:
  • the importer obtains financing from an Islamic bank;
  • goods are purchased from exporter/supplier;
  • financing is arranged through continuous supply mechanism.
Istijrār serves as an alternative to:
  • murābahah financing;
  • tawarruq financing.


Q3: What is the role of the Islamic bank in istijrār import financing?
Answer
The Islamic bank facilitates:
  • payment to exporter;
  • issuance of letter of credit;
  • trade financing for importer.
The arrangement may involve:
  • bank controlling goods; or
  • direct delivery to importer.


Two Types of Delivery Arrangement in Istijrār
1. Bill of Lading Controlled by the Bank
Explanation
The Islamic bank:
  • retains control over shipping documents;
  • controls ownership/title of goods during shipment.
The bill of lading is issued:
  • in the bank’s name.
Thus:
  • the bank has constructive possession (qabd hukmī) over goods.


Case Study 1: Bank Controls Goods
A Malaysian importer wishes to import:
  • electronic equipment from Japan.


Transaction Structure
Step 1
Islamic bank issues:
  • letter of credit to Japanese exporter.


Step 2
Exporter ships goods.
The:
  • bill of lading is issued in bank’s name.
Thus:
  • the bank controls goods during shipment.


Step 3
Bank finances importer through istijrār arrangement.
Importer gradually purchases goods from bank.


Financing Amount
  • Import cost = RM2,000,000
  • Selling price to importer = RM2,300,000


Bank’s Profit
2{,}300{,}000 - 2{,}000{,}000 = 300{,}000
2{,}300{,}000 - 2{,}000{,}000 = 300{,}000


Analysis
The bank:
  • obtains constructive possession through bill of lading;
  • assumes ownership risk during shipment.
Result
✅ Sharī‘ah-compliant istijrār trade financing.


2. Bill of Lading Not Controlled by the Bank
Explanation
In this structure:
  • goods are shipped directly to importer;
  • the bank does not control shipping documents.
The importer:
  • receives goods directly from exporter.
The bank:
  • still finances the trade arrangement through agreed istijrār facility.


Case Study 2: Direct Delivery to Importer
A food importer purchases:
  • frozen meat products from Australia.


Transaction Structure
Step 1
Islamic bank issues:
  • letter of credit.


Step 2
Exporter ships goods directly to importer.
The:
  • bill of lading names importer directly.
Thus:
  • bank does not physically or constructively control goods.


Step 3
Importer settles financing progressively with bank under istijrār arrangement.


Financing Details
  • Import value = RM1,500,000
  • Payment by importer over 12 months = RM1,700,000


Bank’s Profit
1{,}700{,}000 - 1{,}500{,}000 = 200{,}000
1{,}700{,}000 - 1{,}500{,}000 = 200{,}000


Analysis
  • Goods move directly to importer.
  • Bank provides financing facility.
  • Continuous supply relationship exists.
Result
✅ Permissible istijrār-based financing arrangement.


Q4: Why is istijrār useful in Islamic trade finance?
Answer
Istijrār is beneficial because:
  • it facilitates repeated trade transactions;
  • reduces need for repeated separate contracts;
  • supports import-export financing;
  • simplifies ongoing commercial supply arrangements.
It is especially useful for:
  • wholesalers;
  • importers;
  • manufacturers;
  • commodity traders.


Q5: How does istijrār differ from murābahah and tawarruq?
Istijrār
  • Continuous supply arrangement.
  • Suitable for repetitive transactions.
  • Trade-oriented structure.


Murābahah
  • Single cost-plus sale transaction.
  • Common in asset financing.


Tawarruq
  • Cash liquidity arrangement through commodity trading.
  • Mainly financing-oriented rather than supply-oriented.


Important Principle
Istijrār supports:
  • genuine commercial activity;
  • trade financing;
  • continuous supply relationships.
It provides:
  • a Sharī‘ah-compliant alternative to conventional trade financing,
    while avoiding:
  • ribā-based lending structures.

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Islamic Trade Finance – Chronology Where Bill of Lading Is Sent Directly to Customer (Bank Has No Control)
Example Scenario
A Malaysian importer/customer wants to import:
  • industrial equipment from Germany.
Equipment Price
RM1,000,000
The customer obtains:
  • Islamic trade financing facility.
In this structure:
the Bill of Lading (B/L) is sent directly to the customer,
so:
❌ the Islamic bank does NOT control the goods through the B/L.
This is one of the arrangements mentioned in:
  • istijrār;
  • certain import financing facilities.


STEP 1 — Customer Wants to Import Goods
The customer contacts:
  • German exporter/supplier.
The customer agrees to buy:
  • industrial equipment.


STEP 2 — Customer Requests Financing From Islamic Bank
The customer asks:
  • Islamic bank for import financing facility.
The Islamic bank agrees:
  • subject to financing terms.


STEP 3 — Islamic Bank Issues Letter of Credit (LC)
The Islamic bank issues:
a Letter of Credit (LC)
to the exporter.
The LC guarantees:
✅ payment to exporter
if:
  • exporter ships goods properly;
  • exporter submits required documents.


IMPORTANT DIFFERENCE IN THIS STRUCTURE
The LC instructions provide that:
the Bill of Lading will be issued directly to customer/importer,
NOT:
  • to the bank;
  • not “to the order of the bank.”
Thus:
❌ bank does not control shipment documents.


STEP 4 — Exporter Ships Goods
The exporter loads:
  • industrial equipment onto ship.
The shipping company then issues:
Bill of Lading (B/L).


STEP 5 — Bill of Lading Names Customer
The B/L states:
Consignee
➡ Customer/importer directly.
NOT:
  • Islamic bank.
Thus:
✅ customer directly controls release of goods.


IMPORTANT CONSEQUENCE
Because customer is consignee:
  • customer can directly claim goods from shipping company.
The bank:
❌ does not possess constructive control over goods through B/L.


STEP 6 — Exporter Receives Original B/L
The exporter physically receives:
  • original shipping documents.


STEP 7 — Exporter Submits Documents to Bank
The exporter still submits:
  • invoice;
  • B/L copy/original;
  • shipping documents
to bank for payment under LC.
Why?
Because:
  • bank promised payment through LC.


STEP 8 — Islamic Bank Pays Exporter
After checking documents:
✅ bank pays exporter.


STEP 9 — Ship Arrives in Malaysia
The ship reaches:
  • Malaysian port.
Since:
  • customer already named consignee in B/L,
the customer:
✅ can directly collect goods from port.


STEP 10 — Customer Repays Bank
The customer later settles:
  • financing obligation with Islamic bank,
    according to financing arrangement.


IMPORTANT DIFFERENCE FROM BANK-CONTROLLED B/L
In Bank-Controlled Structure
B/L Names
➡ bank.
Result
✅ bank controls goods.


In Direct-to-Customer Structure
B/L Names
➡ customer.
Result
❌ bank does not control goods through B/L.


Ownership and Control in This Structure
During Shipment
Usually:
✅ customer may already have direct control rights through B/L.
The bank’s role mainly becomes:
  • payment financier;
  • LC issuer.


Why Would This Structure Be Used?
It may be used:
  • for commercial convenience;
  • where importer has strong creditworthiness;
  • where bank accepts lower documentary control.


Islamic Finance Perspective
This structure creates:
  • less direct ownership/control by bank.
Therefore:
  • Sharī‘ah structuring becomes more sensitive.
Islamic banks must ensure:
  • financing does not become merely cash lending with profit.
This is why:
  • bank-controlled B/L structures are often preferred in murābahah trade financing.


Chronological Summary
Step 1
Customer wants to import goods.

Step 2
Customer requests Islamic financing.

Step 3
Islamic bank issues LC.

Step 4
Exporter ships goods.

Step 5
Shipping company issues B/L directly to customer.

Step 6
Exporter submits documents to bank.

Step 7
Bank pays exporter.

Step 8
Ship arrives Malaysia.

Step 9
Customer directly collects goods.

Step 10
Customer repays financing to bank.


Important Principle
If B/L Names Bank
➡ bank controls goods.
If B/L Names Customer
➡ customer controls goods directly.
The:
Bill of Lading determines practical control and right to claim the shipment from the carrier.

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Islamic Trade Finance – What Happens to Ownership When a Letter of Credit (LC) Is Issued?
Short Answer
Issuing a Letter of Credit (LC) alone:
does NOT automatically transfer ownership of the goods to the bank.
Ownership depends on:
  • the underlying sale contract;
  • when ownership transfer occurs;
  • who purchased the goods.
The LC itself is mainly:
a payment undertaking by the bank.


Important Principle
Letter of Credit (LC)
➡️ payment mechanism.
Bill of Lading (B/L)
➡️ control/possession document.
Sale Contract
➡️ determines ownership.


Chronological Ownership Explanation
Example Scenario
A Malaysian customer wants to import:
  • a Toyota car from Japan.
Car Price
RM200,000
The customer requests:
  • Islamic bank financing through murābahah.


STEP 1 — Customer Requests Financing
Customer asks:
“Please finance the import of this car.”
At this point:
❌ nobody new owns the car yet.
The exporter still owns the car.


STEP 2 — Islamic Bank Issues Letter of Credit
The Islamic bank issues:
a Letter of Credit (LC)
to exporter.


IMPORTANT POINT
At this stage:
❌ ownership still does NOT transfer to bank merely because LC is issued.
Why?
Because:
  • LC is only a promise to pay;
  • not a sale contract by itself.
Thus:
✅ exporter still owns the car.


STEP 3 — Exporter Ships the Car
Exporter loads car onto ship.
The shipping company issues:
  • Bill of Lading (B/L).
The B/L names:
  • Islamic bank;
    or
  • “to the order of Islamic bank.”


Does B/L Automatically Transfer Ownership?
Not necessarily.
The B/L mainly gives:
✅ control over delivery/access to goods.
Ownership depends on:
  • underlying purchase contract;
  • commercial terms.


STEP 4 — Bank Pays Exporter
After exporter submits compliant documents:
  • Islamic bank pays exporter.
Now we ask:
Did the bank purchase the car from exporter?


IF YES → Ownership Transfers to Bank
In Islamic murābahah financing:
usually:
✅ the bank purchases the goods from exporter first.
Thus:
  • ownership transfers to bank;
  • bank bears ownership risk;
  • bank controls B/L.
Now:
✅ bank owns the car during shipment.


STEP 5 — Bank Sells Car to Customer
The bank later sells:
  • the car to customer through murābahah.
Example:
  • Bank cost = RM200,000
  • Murābahah price = RM230,000
Profit
230,000 - 200,000 = 30,000



STEP 6 — Ownership Transfers to Customer
After murābahah sale:
✅ ownership transfers to customer.
The bank then:
  • endorses/releases B/L to customer.
The customer:
  • collects car at port.


VERY IMPORTANT DISTINCTION
LC Alone Does NOT Create Ownership
Issuing LC only means:
“The bank promises to pay.”
It does NOT automatically mean:
“The bank owns the goods.”


Ownership Comes From Sale Contract
Ownership usually transfers when:
  • bank actually purchases goods from exporter.


Role of B/L
The B/L helps establish:
✅ constructive possession (qabd hukmī)
and
✅ control over delivery.
But:
  • B/L itself is not always the sole determinant of ownership.


Simplified Ownership Timeline
Before LC
Exporter owns car.

After LC Issued
Exporter STILL owns car.

After Bank Purchases Goods
Bank becomes owner.

During Shipment
Bank usually owns and controls goods through B/L.

After Murābahah Sale
Customer becomes owner.

After B/L Endorsed
Customer collects car.


Islamic Finance Perspective
This distinction is crucial because:
  • Islamic banks cannot merely:
    • lend money with profit.
Instead:
✅ bank must genuinely:
  • purchase goods;
  • own goods;
  • bear ownership risk;
  • then resell goods.
Otherwise:
❌ transaction may resemble ribā-based financing.


Important Principle
LC
➡️ payment guarantee.
B/L
➡️ control and constructive possession.
Ownership
➡️ determined by actual sale contract and transfer of ownership rights.

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Islamic  Contract – Chronological Flow of Letter of Credit (LC) and Bill of Lading (B/L)
Example Scenario
A Malaysian customer wants to import:
  • a Toyota car from Japan.
Car Price
RM200,000
The customer asks:
  • an Islamic bank to finance the import transaction.
The Islamic bank uses:
  • a Letter of Credit (LC).


STEP 1 — Customer Requests Financing
The customer approaches the Islamic bank and says:
“I want to import a car from Japan but I need financing.”
The Islamic bank agrees to finance the transaction.


STEP 2 — Islamic Bank Issues Letter of Credit (LC)
The Islamic bank sends:
a Letter of Credit (LC)
to the Japanese exporter.


What Is the LC?
The LC is:
the bank’s promise to pay the exporter
provided:
  • exporter ships the goods properly;
  • exporter submits required shipping documents.


Important LC Instruction
The LC states:
the Bill of Lading (B/L) must be issued:
  • “to the order of the Islamic bank”
    or
  • naming the bank as consignee.


Why Does the Bank Want This?
Because:
  • the bank is paying first;
  • the bank wants control over the goods;
  • the bank must establish ownership/control for Sharī‘ah compliance.


STEP 3 — Exporter Ships the Car
The Japanese exporter:
  • loads the car onto the ship.
Now:
  • the shipping company receives the car for transportation.


STEP 4 — Shipping Company Issues Bill of Lading (B/L)
After receiving the car,
the shipping company prepares:
the Bill of Lading.


What Is the Bill of Lading?
The B/L is:
  1. receipt of goods;
  2. shipping contract;
  3. document of title/control over goods.


IMPORTANT PART
The B/L says:
Consignee
➡ Islamic bank
or
➡ “to the order of Islamic bank.”
Meaning:
the shipping company will only release the car to whoever lawfully holds the endorsed original B/L.


Why Does the B/L Give Control Over Goods?
Because:
  • the port/shipping company refuses to release goods without the original B/L.
Thus:
whoever controls the original B/L effectively controls access to the goods.


STEP 5 — Exporter Receives Original B/L
The shipping company physically gives:
  • the original B/L documents
    to the exporter.


Important Clarification
Although:
  • exporter physically receives the B/L first,
the B/L legally names:
  • the Islamic bank as consignee/controller.
Thus:
  • exporter cannot simply release goods himself.
The exporter’s purpose now is:
to submit documents to the bank and obtain payment.


STEP 6 — Exporter Submits Documents to Bank
The exporter sends:
  • original B/L;
  • commercial invoice;
  • insurance documents;
  • packing list
to the Islamic bank.
This happens:
  • while the ship is still travelling.


STEP 7 — Bank Checks Documents
The Islamic bank examines whether:
  • shipment complied with LC terms;
  • documents are correct.
If everything complies:
✅ bank pays exporter.


STEP 8 — Bank Now Controls the Goods
Now the bank possesses:
  • the original B/L.
Thus:
✅ the bank controls release of the car.
Why?
Because:
  • the shipping company only releases goods to:
    • lawful holder of original endorsed B/L.


STEP 9 — Ship Arrives in Malaysia
The ship reaches:
  • Port Klang.
BUT:
❌ customer still cannot collect the car yet.
Why?
Because customer still does not possess:
  • endorsed original B/L.


STEP 10 — Bank Releases/Endorses B/L to Customer
After:
  • financing documents signed;
  • murābahah completed;
  • customer obligations fulfilled,
the bank:
  • endorses/releases the B/L to customer.
This endorsement means:
the bank transfers the right to claim the goods.


STEP 11 — Customer Presents B/L at Port
The customer now presents:
  • original endorsed B/L
    to shipping company/port authority.
The port verifies:
  • authenticity;
  • endorsement chain.


STEP 12 — Shipping Company Releases the Car
Once verification completed:
✅ shipping company releases the car to customer.
Now:
✅ customer obtains possession of the car.


Overall Timeline Summary
Step 1
Customer requests financing.

Step 2
Islamic bank issues LC.

Step 3
Exporter ships car.

Step 4
Shipping company issues B/L naming bank.

Step 5
Exporter receives B/L physically.

Step 6
Exporter submits B/L to bank.

Step 7
Bank checks documents and pays exporter.

Step 8
Bank now controls goods through B/L.

Step 9
Ship arrives Malaysia.

Step 10
Bank endorses/releases B/L to customer.

Step 11
Customer presents B/L at port.

Step 12
Shipping company releases car.


Islamic Finance Perspective
This structure is important because:
  • Islamic bank must genuinely:
    • own/control goods;
    • bear ownership risk.
The B/L helps establish:
constructive possession (qabd hukmī)
which supports:
  • murābahah financing;
  • istijrār financing;
  • Sharī‘ah-compliant trade finance.
Without such ownership/control:
  • the arrangement may resemble:
    ❌ conventional interest-based lending.


Important Principle
The:
original endorsed Bill of Lading represents legal control and right to claim the goods.
Therefore:
  • whoever lawfully possesses the endorsed B/L generally controls:
    • release;
    • access;
    • practical possession of the shipment.




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