Islamic Banking Risk Management Insights
Islamic Banking Risk Management Insights
FINANCIAL INSTITUTIONS
WAEL EID
Chief Risk Officer & Member of the Investment Committee,
QInvest, Doha, Qatar
Dr Wael Eid is the Chief Risk Officer and member of the Investment Committee at
QInvest. He has extensive experience in Risk Management and Islamic banking in the
Middle East and Europe, with specific expertise in investment and credit risks, financial
analysis, and financial regulation.
Prior to his role at QInvest, Wael served as Chief Risk and Governance officer at SEDCO
Holding, where he chaired the Risk Management Committee, advising the CEO and Board
on various aspects of risk.
With over 20 years of experience in Risk Management, Wael has chaired several
committees, including the Audit and Risk Committee at Al Nahdi Medical Company during
its successful IPO, and was deeply involved in setting up the Risk function at the European
Islamic Investment Bank Plc. in London.
Wael holds an MBA with Distinction from Warwick Business School, and a PhD in Islamic
risk management from Durham University. He is the winner of the 2015 Golden Peacock
Award for Risk Management by the prestigious Institute of Directors (IoD) and is the joint
author of Mapping the Risks and Risk Management Practices in Islamic Banking published by
John Wiley & Sons.
Wael Eid
Chief Risk Officer
Presented at the
Durham Islamic Finance Summer School 2023
Durham Centre for Islamic Economics and Finance
Durham University Business School, UK
31st July – 4th August 2023
Agenda
What is Risk Management?
Interest
Creditors
Risks
Defaults Profit + loss
Profit + loss
Islamic
banking Bank Profit and
loss
Counterparty
Investors Defaults
Profit + loss
• Risks in Islamic banking are more contract-centric than in conventional banking, where risks tend to be more product-centric.
• This special relationships between the contracting parties in Islamic finance, which sometimes changes during the different stages of
the contract, has an impact on risk management.
§ Are Islamic banks more or less risky than their conventional peers?
§ Could the recent crisis have occurred under an Islamic banking system?
Are Islamic banks more or Could the recent crisis How developed and Is there divergence between
less risky than their have occurred under an significant is hedging to the current practice & moral
conventional peers? Islamic banking system? Islamic banking? principles of Islamic bank?
Income statement
structure and External fraud Financial infrastructure Contagion
profitability
Employment practices
Capital adequacy Legal infrastructure Banking crisis
and workplace safety
Clients, products and
Credit Legal liability Other exogenous risks
business services
Damage to physical
Liquidity Regulatory compliance
assets
Business disruption &
Reputational and
Market system failures
fiduciary
(technology risk)
Execution, delivery, and
Interest rate Country risks
process management
Systems
Operational risk Concentration risk
Generic
Islamic
Legal risk Regulatory risk
Bank
Unique
Corporate Displaced
governance risk commercial risk
Systems
Operational risk Concentration risk
Generic
Islamic
Legal risk Regulatory risk
Bank
Unique
Corporate Displaced
governance risk commercial risk
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Credit risk is generally defined as the risk of loss arising from default or failure to
perform. It is also referred to as ‘default risk’, which is one of the earliest recognized
risks in the financial industry. Traditionally, a large part of a bank’s profit came from
the lending businesses, and the majority of bank’s losses were also related to this
aspect of risk management; hence the focus was primarily on credit risk.
First access to Credit risk Risk issues in In bay’ al-salam Risk issues IFIs are IFIs have less
collateral but issues Mudaraba contracts, the under prohibited from sophisticated
foreclosure is in Murabaha investments IFI is exposed to Istisna’a charging credit risk
difficult additional risks contracts accrued interest management
practices
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§ Only 55 percent of GCC companies disclose the main executive positions of board
members, compared with 100 percent in Europe.
§ Name lending
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2. Market risk was recognized in the late eighties, after the increasing importance of stock markets, when
banks started investing heavily in securities.
3. Market risk is difficult to measure due to diversified portfolios, since it will consist of several markets,
currencies, indexes, and instruments. The larger the diversification of the portfolio, the more difficult
it is to accurately estimate market risks due to the correlation between risks.
4. There are several ways to measure and manage market risks, which vary among banks. Most banks
have limits and triggers for portfolios, individual transactions, sectors, and even for traders. Banks
also use marking to market, stop-loss provisions, gap analysis, back testing, and stress testing for their
daily risk management of banking and trading books. Stress testing is gaining more popularity to help
predict expected losses.
5. Factor sensitivities and VaR can be used for market-to-market trading. VaR is the most well-known
methodology to quantify and evaluate market risk in a systematic fashion. It is one of the newer risk
management tools that indicates how much a firm can lose or make with a certain probability in a
given time horizon.
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Rate of
return risk
(profit rate
risk)
Commodity Equity
and price investment
risks risk
Characteristics
of market risk
Currency Mark-up
risk risk
Benchmark
risk
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Limited availability Shallow secondary Absence of lender of Wide maturity Certain characteristics
of Shariah- market last resort mismatches of some Islamic
compliant liquidity between assets & finance instruments
management liabilities: funding give rise to liquidity
instruments conundrum risks.
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IFIs are truly – and often more visibly – subject to the constant trade-off between
profitability and liquidity in a binary way
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CASE STUDY
Example of Imbalanced Funding Continuum
Imbalanced funding continuum heavily reliant on short-term customer
8,000,000 deposits to fund long-term assets
6,000,000
Short-term liabilities to fund
longer-term assets
4,000,000
2,000,000
-2,000,000
Negative liquidity gap in the
short-term
-4,000,000
-6,000,000
0-30 days 31-90 d ays 91-1 year 1-5 years 5 years +
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LIQUIDITY RISK
1 2 3
4
5 6 3
4
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§ For years it was regarded as a star performer and the quality of its assets were
never questioned
§ Having failed to find a commercial buyer for the business, it was taken into
public ownership in 2008, and was then bought by Virgin Money in 2012.
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§ The IIFM has plans to co-operate with the International Capital Market
Association (ICMA) to develop a repo-type liquidity management tool in
order to manage overnight liquidity more efficiently in the future.
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1 2
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Provisions from income PSIA capital & PER + Capital & IRR Takaful
Frequency of losses
High
frequency
Size of losses
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SOURCES OF FUNDS
Islamic vs. Traditional Banks
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OPERATIONAL RISK
§ Historically, operational risk has been defined as all risks other than market, credit, and liquidity
risk. However, the BCBS has narrowed this definition within Basel II by stating that operational risk
is “The risk of loss resulting from inadequate or failed internal processes, people or systems or
from external events.” This definition includes legal risk, but excludes strategic and reputational
risk.
§ Operational risks are rather difficult to measure and manage because these risks only become
apparent once a problem arises. Risks associated with operational risk could include:
i. Internal fraud
ii. External fraud
iii. Employment practices and workplace safety
iv. Clients, products and business practices
v. Damage to physical assets
vi. Business disruption and system failures
vii. Execution, delivery and process management
§ Banks often use internal audit ratings, quality self-assessments, operation risk indicators or Key
Risk Indicators (KRIs) such as volume, turnover, or rate of errors, income and loss volatilities, etc.
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§ Failure of the internal control system to detect and manage potential problems in the
operational process and back-office;
§ Documentation risk is higher for Islamic banks than for conventional bank‘s partly as a
result of the lack of standardisation in the contracts and also because any deficiencies
in the documentation could make the contract unenforceable
§ Potential costs and risk of monitoring equity-type contracts and the associated legal
risk;
§ Technology risk
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CASE STUDY I
(1) Barings Bank
§ In February 1995, Nick Leeson, a rogue trader from Barings Bank, UK, single-handed caused the
financial collapse of a bank that had been in existence for hundreds of years.
§ Barings had been the United Kingdom's oldest investment bank; it had financed the Louisiana
Purchase between the US and France in 1803, and it was Queen Elizabeth’ s favorite bank.
§ Leeson was dealing in risky financial derivatives in the Singapore office of Barings and was betting
heavily on options for both the Singapore and Nikkei exchange indexes.
§ There was no direct oversight of his book and he even set up a dummy account to funnel losing
trades.
§ In January 1995, a huge earthquake hit Japan, sending financial markets reeling, which adversely
affected Leeson’s position.
§ By late February, he faxed a letter of resignation and when his position was discovered, he had lost
USD 1.4 bn.
§ Barings became insolvent and was sold to a competing bank for USD 1.00!
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CASE STUDY I
(1) Barings Bank
Discussion Questions: Group Exercise
§ How was it that Mr. Leeson was able to hide account number 88888 from the
rest of Barings Bank?
§ Was Mr. Leeson really responsible for the collapse of Barings Bank?
§ What are the lessons learnt from the collapse of Barings Bank?
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CASE STUDY I
(1) Barings Bank
1
Management failed to institute proper control
systems
2
Lack of adequate segregations between various
functions
3 Systems of check and balances failed at number of
levels
4
Dubious practices designed to conceal losses
5
Quick profits and greed controlled the game
overriding ethical foundations
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Failure to implement auditor’s recommendations
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1 2
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“Since Shariah non-compliance is the highest risk facing IFIs, a separate session is dedicated to practical steps for regulatory supervision of IFIs.
Fiduciary Risk
A lower rate of return than the Fiduciary risk can be caused by Fiduciary risk can be caused by While, the justification for the
market rate also introduces breach of contract by the Islamic breach of contract by the Islamic Islamic banks’ business is in
fiduciary risk, when bank. bank. compliance with Shariah, an
depositors/investors interpret a inability to do so or not doing so
low rate of return as breaching willfully can cause a serious
of investment contract or confidence problem.
mismanagement of funds by the
bank (AAOIFI 1999).
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Given the different nature of As there are no standard form of Lack of standardized contracts along
financial contracts, Islamic contracts for various financial with the fact that there are no
banks face risks related to instruments, Islamic banks prepare litigations systems to resolve problems
their documentation and these according to their associated with enforceability of
enforcement. understanding of the Shariah, the contracts by the counterparty increase
local laws, and their needs and the legal risks associated with the
concerns. Islamic contractual agreements
Reputational Risk: Accounting Regulatory & Risk categories are Corporate Governance Risk management Short Track
in 2006, there was US state enforcement Standards Tax Issues entangled. Risk issues in sukuk Record
action against Doha Bank’s Islam ic Conglomeration of Case studies :
banking arm in its New York branch
risks: each mode of 1- Ahmad Hamad Algosaibi
relating to insufficient anti-money
laundering controls and systems. In April finance carries various 2- Saad Group
2009, Doha Bank paid a fine of USD 5 risks bundled together
million, which was imposed by two US
governm ent agencies: the Financial
Crimes Enforcement Network and the
Office of the Comptroller of the
Currency.
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The East Cameron Partners L.P. (ECP) sukuk was relatively small one at USD 165.67 million
and was issued in July 2006. It was the first issued by a US company and was a genuine
effort at an asset-backed Musharaka. It was secured by an interest in the oil and gas royalty
rights on two gas fields in the Gulf of Mexico. On 16 October 2008, East Cameron Partners
(the originating company), filed for Chapter 11 / bankruptcy in the US courts.
A sukuk enforcement event was then triggered on 3 September 2008 due to a shortfall in
the stressed oil and gas reserves. With an asset-backed structure sukuk investors already
have legal rights over the oil and gas assets but ECP requested a ruling that the transaction
was not a ‘true sale’ but a ‘secured loan’. In the former, sukuk investors have sole rights to
the assets in the latter they would lose their rights and share the assets with the other
creditors should ECP enter Chapter 7 (liquidation).
Ultimately providing asset security for investors is a legal issue that impacts conventional
and sukuk structures equally. The concept is well tested in the US so investors’ rights should
be preserved if structured correctly. In the Middle East, legal systems are less tested and
secured sukuk are the minority. Investors in asset-based sukuk have no senior claim or lien
over the sukuk assets – but this is deliberate and clear to most parties.
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§ Islamic banks reluctant to apply PLS technique in the case of losses fearing a
much higher risk of a Rush, leading to loss of liquidity, reputation, and
business, rendering its continuity questionable
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The rotten heart of finance: The root of all financial crises is a similar fault – greed and
lack of morality.
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When the short-terms risks and the longer-term stability are put together and optimised,
the outlook for the Islamic banking industry looks less risky than its critics claim.
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Wael Eid
Chief Risk Officer
[email protected]
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