Towards a Russian Model of Islamic Banking: Legal Lessons from Bahrain, Indonesia, and the UAE

Islamic banking law is a growing matter in the Islamic world. This kind of banking law which is based on Sharia, recently has played a big role in attracting foreign investments in Islamic states. The significant impact of this banking system has made some states to adopt a precise legal framework for their Islamic banking; As the United Arab Emirates in 1985, Bahrain in 2006 and Indonesia in 2008 have approved their Islamic banking laws. Russia, as a state with Muslim republics, adopted the Islamic Banking Law which entered into force in four republics, namely Republic of Bashkortostan, Tatarstan, Dagestan and Chechnya on September 1, 2023. Purpose: The main purpose of the paper is to answer the basic question: What is a good framework of Islamic banking law which can attract foreign investments? Method: the qualitative and general logical methods, as well as research techniques are used in analyzing shariah law especially Islamic banking contracts and the complying the Russian banking law with the Sharia framework. Results: considering the United Arab Emirates Law No. 6 of 1985 on Islamic banks, the law No. 21 of 2008 on Islamic banking of Indonesia and Bahrain Islamic banking regulatory framework No. 64 of 2006 as a comprehensive Islamic banking laws and analyzing the new Russian banking law, I came to the conclusion that a good framework of Islamic banking law which attracts foreign investment is based on four criteria i.e. Islamic basis, Islamic contracts, Islamic financial institutions and Islamic supervision.