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Visitation by International Center for Development in Islamic Finance – Indonesian Banking Development Institute (ICDIF-LPPI),
Indonesia
SHARIAH FRAMEWORK & GOVERNANCE IN BANK ISLAM
Mohd Nazri Bin ChikAssistant General Manager, Shariah Division
24th June 2013/ 15th Syaaban 1434
Strictly Private & Confidential
Introduction to Shariah Governance
TOPIC 1TOPIC 1
IFSB-10 Guiding Principles on Shariah Governance Systems for Institutions Offering Islamic Financial Services defines:
“A set of institutional and organisational arrangements through which Islamic financial institutions ensure that there is an effective independent oversight of Shariah compliance over the issuance of relevant Shariahpronouncements, dissemination of information and an internal Shariahcompliance review.”
This requires:1.A set of institutional and organisational arrangement – Board of Directors, Shariah committee, Shariah division, internal audit function.
2.An effective independent oversight on Shariah compliance
3.Shariah pronouncements, disseminations of info and an internal Shariah review – ex-ante and ex-post aspects of the Shariah compliance framework.
WHAT IS SHARIAH GOVERNANCE?
DISSEMINATIONOF SHARI’AHRESOLUTIONS
ISSUANCE OFSHARI’AH
RESOLUTIONS
ANNUALSHARI’AHREVIEW
PERIODICINTERNALSHARI’AHREVIEWS
EX‐ANTE
EX‐POST
IMPLICATIONS OF SHARIAH NON‐COMPLIANCES?
Page 5
IMPACT OF SNC
• Shariah non-compliant income due to invalidation of contract (‘aqad)
• Capital adequacy ratio (CAR) impact
• Against the commands of Allah SWT
• Impediment of Allah’s SWT blessing or barakah
• Jeopardize business reputation
Contravention of the Islamic Financial Services Act 2013:
Section 28(5) of the Act providesImprisonment for a term not exceeding eight years; or
Fine not exceeding twenty-five million ringgit; or both.
FINANCIAL NON-FINANCIAL
REGULATORY
MODELS OF SHARIAH GOVERNANCE
Shariah‐CompliantProcess
Regulatory Framework of Shariah Governance
TOPIC 2TOPIC 2
Effective date 1 January 2011 and Islamic banks are given 6 (six) months to comply with all requirements.
IFI to confirm status of compliance with SGF at the end of the six months. Full enforcement 1 July 2011.
Objectives:Set out the expectation of BNM on Shariah governance structures, processes and arrangements to ensure that all its operations andbusiness activities are in accordance with Shariah.Provides a comprehensive guidance to the Board, ShariahSupervisory Council and management of the Bank in discharging its duties in matters relating to Shariah; andOutlines the functions relating to Shariah review, Shariah audit, Shariah risk management and Shariah research.
BNM’S SHARIAH GOVERNANCE FRAMEWORK
GuidingPrinciples
Oversight, accountability & ResponsibilityClear demarcations on accountability &responsibility
Board overall accountabilitySC accountability on decisions, views & opinionsManagement’s responsibility in providing adequate support
IndependenceRecognition by board on SC’s independenceAppropriate reporting structureSC decision shall not be set asideAccess to necessary info by SCAppointment & removal of SC
CompetencyComply to fit & proper requirementContinuous training provided to key internal stakeholdersPerformance assessment for SCSuccession planning program for SC
Confidentiality & consistency
Duty to observe confidentiality on sensitive info obtained by SCRestriction on SC membership in IFI within same industryStructured decision making processSC should not undermine SAC rulings
Source: Bank Negara Malaysia
FRAMING SHARIAH GOVERNANCE FRAMEWORK
Shariah Principle in Islamic finance
MANAGEMENTEnsure executions of business & operations
are in accordance with Shariah rules & principles
Provide necessary support to the Shariah committee
BOARDOverall oversight on
Shariah compliance & review
BOARD AUDIT COMMITTEE
BOARD RISK MANAGEMENT
COMMITTEE
Shariah Review FunctionReview business operations on a regular basis to ensure
Shariah compliance
Shariah Risk Management Control Function
Identify, measure, monitor, report & control Shariah
non-compliance risk
SHARIAH COMMITTEEOversight accountability on
Shariah related matters
Shariah Audit FunctionProvide independent
assessment & objective assurance designed to value
add & improve IFI’s compliance with Shariah
Shariah Research Function
Conduct comprehensive Shariah research prior to submission to the Shariah
committee
Shariah compliance and Research Functions
Source: Bank Negara Malaysia
SHARIAH GOVERNANCE FRAMEWORK’S MODEL
Shariah Review Shariah Audit
ScopeScope
ObjectiveObjective
ProcessProcess
To ensure that the activities and operations carried out by the IFI do not contravene with the Shariah
To provide an independent assessment & objective assurance to ensure a sound and effective internal control system for Shariah compliance
Overall business operations, including the end‐to‐end product development process (from product structuring to product offering)
Planning the review program (including objectives, scope, reporting, rectification and follow‐up actions followed by the execution of the program);
Documentation of the processes involved;
Communicating the outcome & highlighting any non‐compliances to the Shariah Committee & the management; and
Rectifying any instances of Shariah non‐compliance to prevent such events from recurring.
All aspects of the IFI’s business operations & activities, including:
audit of financial statements;
compliance audit on organisational structure, people & IT application systems; and
review of adequacy of the Shariah governance process.
Understanding the business activities of the IFI – to allow for better scoping of an audit exercise;
Developing a comprehensive internal audit program;
Obtaining and making reference to relevant sources (e.g. SAC’s published rulings, the SC’S decisions, etc)
Communicating results or findings to the Board Audit Committee and the Shariah Committee; and
Providing recommendations on rectification measures taken as well as following‐up on the implementation by the IFI.
Source: Bank Negara Malaysia
SHARIAH REVIEW AND SHARIAH AUDIT FUNCTIONS
Shariah risk management control
Shariah risk management control
Shariah research function
Shariah research function
Shariah secretariat function
Shariah secretariat function
Apart from Shariah review & audit IFIs are also expected to establish other functions that complement and provide necessary support to Shariah compliance functions within the organisation
Objectives Scope & Functions
Form part of IFIs integrated risk mgmt control function
Identification & assessment of Shariah risk would be systematically controlled & monitored
Perform in-depth research on Shariah including providing day-to-day Shariah advice & consultancy
Perform by qualified Shariah officers
May seek input from experts on technical matters
Coordinating meetings, compiling papers, disseminating Shariah decisions
Engaging with relevant parties that need assistance
Ensure proper deliberation of Shariah related matters
Provide necessary support to Shariah committee & IFI in implementing Shariah governance
Source: Bank Negara Malaysia
OTHER KEY INTERNAL FUNCTIONS
Shariah Supervisory Council
Board of Directors
Board Risk Committee
MRCC
ORCC*
Shariah Division
Audit & Examination Committee
Internal Audit Division (Shariah
audit)
ZakatCommittee
Managing Director
Note:SCRM – Shariah Compliance Risk ManagementMRCC – Management Risk Control CommitteeORCC – Operational Risk Control Committee
– Administratively– Functionally
* w.e.f July 2012. Previously Shariah non compliance risk was over sighted by Shariah Compliance Risk Control Committee.
Shariah Review
Committee
BANK ISLAM'S INTERNAL SHARIAH GOVERNANCE
TOPIC 3TOPIC 3
Shariah Non‐Compliance Risk Management
Guiding Principles:
Principle 7.1: IIFS shall have in place adequate systems and controls, including Shariah Board/ Advisor, to ensure compliance with Shariah rules and principles.
comply at all times with the Shariah rules and principles.
contract documentation complies with the Shariah – with regard to formation, termination and elements possibly affecting contract performance.
Shariah compliance review at least annually.
keep track of income not recognised arising out of Shariahnon‐compliance and assess the probability of similar cases arising in the future.
Principle 7.2: IIFS shall have in place appropriate mechanisms to safeguard the interests of all fund providers. Where IAH funds are commingled with the IIFS’’s own funds, the IIFS shall ensure that the bases for asset, revenue, expense and profit allocations are established, applied and reported in a manner consistent with the IIFS’’s fiduciary responsibilities.
DEFINITION OF SHARIAH NON‐COMPLIANCE RISK
OPERATIONAL RISK
“Risk of losses resulting from inadequate of failed internal process, people and systems or from external events, which includes legal risk and Shariah non compliance risk, but excludes strategic and reputational risk.”
SHARIAH NON‐COMPLIANCE RISK
“The risk that arises from the Bank’s failure to comply with the Shariah rules and principles determined by the relevant Shariah regulatory councils.”
IFSB -2 (Capital Adequacy Standard) -IFIs are required to set aside 15% of average annual gross income over preceding three (3) years gross for OR.
Regulator has discretion to impose a higher capital charge as they deem fit to cater for SCR of a particular IBI. The percentage is not specified in the IFSB-2 because the extent of losses arising from non-compliance with Shariah rules and principles cannot be ascertained owing to lack of data.
Annual Average Gross Income (previous three years) X 15%
Gross income is defined as:Net income from financing activities (e.g. selling
price less purchase price) which is gross of any provisions and operating expenses; plus
Net income from investment activities; plusFee income (e.g. commission and agency fee)*
Less:Investment account holders’ share of income
Operational Risk Capital Requirement (ORCR)
ORW = 12.5 * ORCR
* BNM’s CAFIB – may include income from Shariah non‐compliant sources, if any.
Malaysia – BNM’s Capital Adequacy Framework for Islamic Banks.Islamic banks may adopt Standardized
Approach (SA) subject to BNM approval.Islamic banks that have adopted SA are not
allowed to revert to BIA without the approval of BNM.
SCR AND CAPITAL ADEQUACY REQUIREMENT
18
BASEL SOUND PRACTICES ON OPERATIONAL RISK
Bank Islam adopted definition of OR as per BNM’s Capital Adequacy Framework of Islamic Banks (CAFIB).
Risk Management Framework of the Bank communicates the Bank’s vision and strategies in managing credit, market, operational, Shariah non compliance and other risks of the Bank.
The RMF is supported by various polices and guidelines.
BANK ISLAM’S RISK MANAGEMENT FRAMEWORK
Bank Islam’s Risk Management Framework is built upon the solah (prayer), the main pillar of Islam.
Risk Management Framework
Operational Risk Management Framework and GuidelineStandard of Control of Operational Risk (SCOR)Risk Loss Event Management and Reporting Guideline
Business Continuity Management PolicyBusiness Continuity Management Guideline
Shariah Compliance PolicyShariah Compliance Risk Management Guideline
Shariah contracts guidelines
RISK POLICIES AND GUIDELINES
RMF is supported by Risk Appetite Framework i.e. the guiding document for any strategic, business and/or risk decision making process. The document reflects the current macro‐economic environment and in line with Internal Capital Adequacy Assessment Process (ICAAP).
RAS 1Responsibility of Senior
Management via MANCO & subject to oversight by Board
RAS 3Periodic review on
comprehensiveness of the Bank’s risks and resources/ processes applied to manage
the risk
RAS 6All employees are
responsible for risk and held accountable
RAS 8Adherence to laws, Shariah principles and tenets. Zero-tolerance to Shariah non-
compliance
RAS 9Adherence to minimum control standards (Standard for the
Control of OR “SCOR)
RAS 10Only undertake well understood activities
RAS 11No compromise on
reputational risk
RAS 14Perform annual ICAAP as part of business & budget
planning. Establish a comprehensive capital plan
RAS 15Strong PIDM rating, minimum
of category 2
RISK APPETITE FRAMEWORK OF BANK ISLAM
BNM’S SHARIAH GOVERNANCE FRAMEWORK REQUIREMENTS ON SCRM
Page 22
PRINCIPLE 7: There shall be a robust Shariah compliance function, comprising review and audit functions, supported by risk management control process and internal
research capacity.
Para 7.15Shariah risk management is a function to systematically identify, measure, monitor and control of Shariah non-compliance risks to mitigate any possible of non-compliance events.
Para 7.16The Shariah risk management control function shall form as part of the bank’s integrated risk management framework.
Para 7.17Due to technicality and complexity in managing the risk of non-compliance to the Shariah, the function shall be performed by risk officers that have suitable qualifications and/or experience in the subject matter.
Shariah Division – Shariah Compliance Risk
BNM’S SHARIAH GOVERNANCE FRAMEWORK REQUIREMENTS ON SCRM (cont.)
Page 23
Para 7.18Shariah risk management function involves:
1) Facilitating the process of identifying, measuring, controlling and monitoring Shariah non-compliance risks inherent in the bank’s operations and activities.
2) Formulating and recommending appropriate Shariah non-compliance risk management policies and guidelines.
3) Developing and implementing processes for Shariah non-compliance risk awareness in the bank.
Shariah Division – Shariah Compliance Risk
REPORTING LINE OF SCRM
Page 24
Head of Shariah
Shariah Compliance Risk
Management
Shariah Supervisory
Council
Operational Risk
Management Department
Managing Director
Chief Risk Officer
Board Risk Committee
Double bold lines – SCRM reports to Head of Shariah and Head of ORM Department
>>
Shariah Division – Shariah Compliance Risk
1ST LINE OF DEFENCE
3RD LINE OF DEFENCE
2ND LINE OF DEFENCE
Line Management (including Business and Support Heads, Branch Managers, BRO, SRO, DORC and all staff)
RESPONSIBLE for ongoing oversight of risk and control at day to day work level.
Operational Risk Mgmt Dept, Compliance &
Control Dept, Operational Risk Control Committee
and SCR Control Committee
ESTABLISH and maintain ORM and SCRM Framework, assessing monitoring, reporting & controlling risk on a bank wide level
Internal Audit (Including Shariah Audit)
PROVIDE INDEPENDENT ASSURANCE to Board of Directors and Senior Management that Risk Management processes and tools are effectively implemented.
ORM AND SCRM STRATEGY
26
SCRM Tools & Processes
Risk Profiling MASA-Shariah MASA-Shariah & SNCTR
MASA-Shariah & SNCTR
• Identify and document SCR to develop risk profile:1. Risk description2. Causal factors3. Controls
• Assess and measure SCR on half-yearly basis (role of BRO and DORC)
MASA-Shariah•Document actions taken/ required to mitigate SCR•Ensure resolution
SNC Tracking •SNC Tracking Report (SNCTR) mostly driven CCD
• Report risk (SNCTR)
• Compliance and Control Department actively drive identification of SCR and document SCR control & residual risk (SCR Profile)
• Monitor submission.• Validate residual
risk
MASA-Shariah•Monitor resolution of actions taken
SNC Tracking •Analyze and monitor
•Develop ShariahPolicy, Guidelines
• Report risk:1. SNCTR2. Shariah Non-
Compliant Income
• Report to Board/ BRC, SRC, MRCC, SCRCC
1ST LOD
2ND LOD
SCRM PROCESSES AND TOOLS
MASA‐Shariah (self assessment) – medium and highRisk Task OIC Comply
(Y/N) Shariah Requirement Additional Control
S1 –Customer is not eligible to transact.
• Financing application creation.
• Handle offer acceptance
PFE • Customer must have capacity to enter into transaction.
• Granting financing to customers who are clearly known not to have the capacity to pay it is prohibited (haram).
S2 –Appointment of Agent Form is not completed and signed.
Financing application creation.
PFE • Shariah Compliance Policy - All documents relating to the products and services must be approved by the SSC.
• To perform as an agent, the Bank must be appointed by the principal.
IDENTIFICATION OF SCR (RISK MAPPING)
REPORTING REQUIREMENTS UNDER BNM’S SGF
29SHARIAH DIVISION
No Section Principle Reporting Frequency
1. Section 1: General Requirements of the SGF
Principle I 1.6 IFI shall establish formal reporting channels among the key functions to ensure that the reporting of Shariah matters is carried out effectively & on timely manner.
• All Shariah non‐compliance events are to be reported to the board of the IFI and Bank Negara Malaysia.
Monthly
2. Section II: Oversight, Accountability & Responsibility
Principle 2 Shariah committee (SC) 2.9 In discharging its duties, the SC is expected to disclose sufficient information in the IFIs annual financial report.
Management 2.17 In the event the management becomes aware that certain operations are found to be carrying out businesses which are not in compliance with Shariah, or against the advice of the SC or the rulings of SAC, the management shall:
• Immediately notify the board and SC as well as Bank Negara Malaysia
Annually
‘As and when’
3. Section III: Independence
Principle 3 3.7 In cases where Shariah non‐compliant activities are not effectively or adequately addressed or no rectification measures are made by the IFI, the SC shall inform the Bank of the fact
‘As and when’
ACTUAL SHARIAH NON-COMPLIANCE REPORTING PROCESS
Shariah Division Page 30
POTENTIAL SHARIAH NON-COMPLIANCE REPORTING PROCESS
Shariah Division Page 31
32
SCR Policy & Guidelines
SHARIAH RELATED POLICY & GUIDELINES
No. Guideline Purpose Outline
1. Shariah Compliance Policy
To ensure that the Bank’s products, services and activities comply with the Shariah requirements as determined by relevant Shariah regulatory councils.
To establish the appropriate functional structures as well as their roles and responsibilities in managing Shariah compliance risk within the Bank.
To define general as well as specific Shariah requirements in deposit, financings, investments and other services offered by the Bank.
Application of Shariah in Islamic Banking Shariah Compliance Risk Management Definition of Shariah Compliance RiskSCRM Methodology SCRM Mission and Objectives SCRM Functional Structure “3 Lines of Defense” ConceptSCRM Policy and Guidelines SCRM Processes SCRM Enablers The Shariah Department SCRM Roadmap General Shariah ComplianceSpecific Shariah Compliance Specific Shariah Compliance on Deposits Specific Shariah Compliance on Services Specific Shariah Compliance on Financing Specific Shariah Compliance on Investment
Shariah Division Page 33
SHARIAH RELATED POLICY & GUIDELINES
No. Guideline Purpose Outline
2. Shariah Compliance Risk Management (SCRM) Guideline
Provides guidance and reference to all staff in understanding the idea of SCRM.
Elaborates the process of managing Shariah compliance risk.
Details out the application of SCRM tools.
SCRM ProcessesRisk IdentificationAssessment and MeasurementControl and MonitoringRisk Reporting
3. Shariah Review Guideline
Provides guidance and/or reference to all staff in understanding Shariah review.
Standardizes and streamlines the methodology and procedures in undertaking Shariah review by relevant staff.
Definition and Objective of Shariah ReviewShariah Review and Shariah AuditShariah Review PolicyShariah Review ReferenceShariah Review CoverageShariah Review PlanNotification of Shariah Review ExerciseIndependent Review ProcessRecord KeepingShariah Review Process
Page 34Shariah Division
SHARIAH RELATED POLICY & GUIDELINES
No. Guideline Purpose Outline
4. Business ZakatPayment Guidelines
Provides a standard guide to be followed by Bank’s staff in managing the payment of Bank’s business zakat;
Sets out the requirements for the Bank’s business zakat payment to ensure compliance with Shariah requirements as determined by the Shariah regulatory councils.
Legality of ZakatEligible Recipients of Zakat (Asnaf) General Requirements Approving Authorities Eligibility Criteria for Fuqara’, Masakin, Fi Sabilillah and MuallafatAl-qulub Recipient Fuqara’ and MasakinFi SabilillahMuallafat Al-qulubRoles and Responsibilities of Related Parties
5. Shariah Division Operational Manual
Acts as a guide for Shariah Division staff in discharging their roles and responsibilities.
Standardises and streamline Bank Islam procedures and practices for Shariah functions.
Shariah Division – Organisation Chart and Job DescriptionStandard Operating Procedure
Shariah Division Page 35
SHARIAH RELATED POLICY & GUIDELINES
No. Guideline Purpose Outline
6.7.
8.
9.10.11.12.13.
Shariah Contract Guidelines
Wadiah Contract GuidelineIjarah and Ijarah Muntahiah bit Tamlik (IMB) GuidelineMusharakah & Mudharabah(Financing) Contracts GuidelineIstisna’ Contract GuidelineMudharabah (Deposit) GuidelineKafalah GuidelineWakalah Contract GuidelineTawarruq (Financing) Concept Guideline
All the Guidelines are to serve:
As a standard guide for the Bank’s personnel in dealing with the Bank’s products based on the respective Shariah contracts.
To set out the requirements for the Bank’s products which are based on the respective Shariahcontracts, to ensure that the planning, development, and implementation of the Bank’s products are in accordance with the Shariah rules and principles.
Definition and BasisModus Operandi Primary Shariah Requirements Specific Shariah Requirements
Shariah Division Page 36
37
SCR Awareness
Page 38
SHARIAH COMPLIANCE TRAINING ‘HIJRAH TO EXCEL’ PROGRAMME
OBJECTIVE OF THE PROGRAMME COVERAGE OF THE PROGRAMME
1. To facilitate the process of ensuring compliance with Shariah requirements in the Bank’s products, services and activities.
2. To instill Shariah compliance risk aware culture within the Bank.
1. Islamic Banking: A Revisit
2. Shariah is Our Foundation
3. Shariah Contracts (sale, deposit, partnership & other supporting contracts)
4. Islamic Ethics
Shariah Division
Page 39
OTHER INITIATIVES
No. Programme
1. Shariah Compliance Risk Masterclass for Senior Management
2. Workshop Sharing Session on Operational Issues for Clerical, Officers, Branch Service Managers and Branch Managers organized by Branch Supervision
3. Refresher course on Shariah compliance risk for high exposure functional areas on SCR. E.g.:1.Credit Administration Department2.Central Financing Processing Centre3.Vehicle Financing Department4.Bank Islam Card Centre5.Trade Finance Department
4. Issuance of Shariah Compliance Risk reminders to staffs
Shariah session during Orientation Programme for newly recruited staff.
The following programmes were and will be organized to instill Shariah compliance risk awareness culture among Bank Islam staff:The following programmes were and will be organized to instill Shariah compliance risk awareness culture among Bank Islam staff:
Shariah Division
40
Shariah Non‐Compliant Income
SHARIAH NON-COMPLIANT INCOME
Shariah Division Page 41
SourcesSources
Disposal policyDisposal policy
RecipientsRecipients
Approval authority for disposal
Approval authority for disposal
1) Pre-identified e.g. Interest from nostro accounts (conventional bank), Bank Islam Card
2) Income derived from SNC with regard to invalid contract between Bank and customer due to operational breach of Shariah rules and principles
1) Pre-identified e.g. Interest from nostro accounts (conventional bank), Bank Islam Card
2) Income derived from SNC with regard to invalid contract between Bank and customer due to operational breach of Shariah rules and principles
The Bank is obliged to dispose the Shariah non-compliant income by way of charity as soon as possibleShariah non-compliant income must be placed in a special accountThe account is under supervision of related departments i.e Finance and Shariah
The Bank is obliged to dispose the Shariah non-compliant income by way of charity as soon as possibleShariah non-compliant income must be placed in a special accountThe account is under supervision of related departments i.e Finance and Shariah
Among recipients of Shariah non-compliant income from Bank Islam are:a) PDK Seri Murni, Sg Siput, Perak. (passenger van)b) Yayasan Amal Malaysia (purchase of land for development of Regional
Dakwah Centre)c) Masjid an-Nur and Surau ar-Rayyan, Wilayah Persekutuan Labuan
(construction and refurbishment of toilet and ablution area)d) Jabatan Hal Ehwal Agama Islam Kelantan (purchase of hearse for rural area)
Among recipients of Shariah non-compliant income from Bank Islam are:a) PDK Seri Murni, Sg Siput, Perak. (passenger van)b) Yayasan Amal Malaysia (purchase of land for development of Regional
Dakwah Centre)c) Masjid an-Nur and Surau ar-Rayyan, Wilayah Persekutuan Labuan
(construction and refurbishment of toilet and ablution area)d) Jabatan Hal Ehwal Agama Islam Kelantan (purchase of hearse for rural area)
All decisions on disposal of Shariah non-compliant income must be approved by Shariah Supervisory Council
All decisions on disposal of Shariah non-compliant income must be approved by Shariah Supervisory Council
Disclaimer: This presentation material has been prepared by Bank Islam Malaysia Berhad (the Bank”) for information purposes only and does not purport to contain all the information that may be required to evaluate the Bank or its financial position. No representation or warranty, express r implied, is given by or on behalf of the Bank as to the accuracy of the information or opinions contained in this presentation. The presentation does not constitute or form part of an offer, solicitation or invitation of any offer, to buy or subscribe for any securities , nor should it or any part of it form the basis of, or be relied in any connection with, any contract, investment decision or commitment whatsoever. The Bank does not accept any liability whatsoever for any loss howsoever arising from any use of this presentation or their contents or otherwise arising in connection therewith.
BANK ISLAM MALAYSIA BERHAD27th Floor, Menara Bank Islam,No. 22, Jalan Perak, 50450 Kuala Lumpur.Tel: 603 2088 8222
www.bankislam.com.my
Mohd Nazri ChikAssistant General Manager, ShariahContact: 603 2088 8052Email: [email protected]