Compliance reaches the product and stops there
We looked at how Islamic products are presented on banks’ own websites — and how the same products are presented in their advertising. The gap turned out to be consistent. It is not about Shariah; it is about scope: the expertise is bought for the product, and communication sits outside it.
The gap
Across public product pages in one market we found three different ways of talking about the price of an Islamic product: one bank writes “no interest and no fees”, another publishes a mark-up formula referencing a market benchmark, a third names no rate at all. The category has no shared language.
The pages themselves are careful work. Some name the body that reviews deal structures; some disclose how pricing is built. At the product level there is little to fault.
Then the same products reach advertising — and the disclosure stays behind on the website. The number travels. The contract, the conditions and the approving body do not.
| Rate | Approving body | |
|---|---|---|
| Product page | disclosed properly, or deliberately not named | sometimes named outright |
| Ad creative | appears as “X% per annum” | not named |
Why it happens. Shariah expertise is normally procured for the product: deal structures, contracts, opinions. Communication is not in scope — neither formally nor organisationally. So the gap opens not through negligence but exactly at the edge of the perimeter. Marketing meanwhile believes the product is “already reviewed”, and that is true — the product was reviewed, not what is said about it.
Two cases
Both verdicts are red — but the creatives break differently. In the first the product is sound and what turns it red is what goes unsaid: nothing discloses what actually protects the savings. In the second it is the product language itself: an interest rate inside an Islamic claim. The first is fixed with one line; the second needs the offer rewritten.
Savings-based housing: a bank-grade trust image with nothing disclosed
- Ethics
- 100
- Culture
- 100
- Tone
- 100
- Finance
- 10
A bank-grade trust image without disclosing that savings are uninsured
A table of fixed instalments and total payments reads as a bank product. In this model savings are not covered by public deposit insurance — and the creative says nothing about it. Not saying so is riskier than saying something wrong: the reader fills the gap themselves.
There is protection here, just a different kind — a regulator’s licence, supervision and a mandatory reserve fund. That is a strong argument, and it goes unused. This is exactly why the finding is a blocker rather than a note: the omission creates a false impression of bank-level deposit protection.
“No credit” as a comparison with no measurable basis
The phrasing places the product above a mortgage without naming a single verifiable parameter of comparison.
The regulation requires an objectively verifiable basis, and the burden of proof sits with the advertiser. The fix is not deletion but specificity: name the parameter and the scenario — for instance, total cost of the asset over N months using published figures.
A payment table with no full-cost block
The instalment and the total are visible — what is not visible is what they exclude: service fee, registration, insurance, notary.
The advertising rules written for participation banks do not apply here: this is not a bank, and the banking association cannot be cited — the general consumer protection law governs instead. The engine tells these two regimes apart and does not borrow the wrong standard.
“Interest-free” is properly grounded — no halal-washing raised
In this segment the description has a regulatory basis: the pool may only be placed in interest-free instruments. The engine deliberately raises nothing here.
A checking layer unable to draw this distinction would produce a false alarm — and would cite rules written for banks while doing it.
From 5,000 a month — no interest, no credit Table: financing · instalment · total payable Savings are not covered by public deposit insurance. Protection: regulator’s licence · supervision · mandatory reserve fund. The table covers financing only; fees, registration and insurance are charged separately.
Islamic business financing: a rate quoted per annum
- Ethics
- 100
- Culture
- 85
- Tone
- 100
- Finance
- 0
An interest rate inside a product carrying an Islamic claim
Ijarah as a contract has no interest rate: the lessor’s return is a fixed rental payment, not a percentage on capital. “From X% per annum” turns the contract into an interest loan at the level of the message — regardless of how the deal is built in the documents.
The distinction many tools miss: on the deposit side “X% p.a.” from a licensed bank is fine — it is the expected return of a Mudarabah. On the financing side the same percentage expresses the price of money over time. One phrase, two different conclusions. A banking licence and an Islamic window do not clear this finding: the window is a normal licensing arrangement, but it does not make a specific product compliant.
The approving body is not named in the creative
The Islamic claim is explicit and the Shariah contracts are named — yet the board or body that approved these products appears nowhere. The audience cannot verify what the word “Islamic” rests on.
On the product page that body is often disclosed properly: the problem is not that it is missing, but that it never reached the advertising. And once an internal Islamic finance council became mandatory, the gap stopped being merely ethical and became regulatory too. That is why this is a blocker rather than a note.
“From 14%” with no material conditions
The rate is presented as a floor: nothing states who qualifies for the minimum, what the range is, what is required of the borrower and the collateral, or what the total cost of financing amounts to.
Even after the wording is moved to a Shariah-correct form — a mark-up, a rental payment — a minimum without disclosure remains a concealment of material terms.
The creative is in Russian only
On this market a single-language creative is not a detail: a large share of the small-business audience lives in Uzbek-language channels, and the absence of Uzbek costs both reach and trust.
The market norm: Uzbek in Latin script is the primary language, Russian is the supplement — not the other way round.
“The price does not change” — the strongest USP, left unused
Rewrite the rate as a fixed final Murabaha price and a fixed Ijarah rental payment, and the core message becomes “the price is known in advance and does not change”.
That lands on two layers of the audience at once: for the practising segment it is the absence of riba, for everyone else it is predictability. For small businesses living on instalment plans it is a direct differentiator from a conventional bank. One edit removes the blocker and delivers the offer.
Islamic financing for your business Murabaha · Ijarah · up to 60 months The price is known in advance and does not change. The rental payment is fixed for the whole term. A trade at a fixed price instead of interest-bearing debt. Product structures approved by [name of the body].
Why the score is not averaged
In both cases ethics, culture and tone sit between 85 and 100. It saves neither creative. The score follows the weakest link, and the finance layer runs as a separate gate: once a blocker is found the verdict is red and the overall Compliance Score is not shown at all, because there is nothing left to average. A weighted average would have produced roughly eighty here and sent both creatives to air.
What to do about it
- Move one line about the approving body into the creative. Not a paragraph — a line. If the website already discloses it, this is copying, not new work.
- Replace the rate with a form that matches the contract. Fixed payment for ijarah, fixed price for murabaha. The economics do not change; the wording does.
- Bring communication inside the scope of the review. This is the only one of the three that needs a decision rather than an edit — and the only one that closes the gap for good.
Boundaries
- This is not a fatwa and not legal advice.
- The compliance decision belongs to the institution’s own competent body; Amanetiq works before it, not instead of it.
- Where a market has no single norm, the verdict says “requires expert review” instead of faking confidence.
- We do not name the approving body on a client’s behalf. Where a suggestion reads “[name of the body]”, it means the person who knows who actually approved the product has to fill it in.