Models of Islamic Banking: Jurisdictional Realities and Emerging Challenges 

This paper explores the different models of Islamic banking across jurisdictions, highlighting how regulatory environments shape their structure and development. It examines the coexistence of full-fledged Islamic banks, subsidiaries, and Islamic windows, particularly in regions without dedicated Islamic banking laws such as parts of Europe and North America.

The study also discusses emerging ownership challenges, including the acquisition of Islamic banks by conventional financial institutions, which raises concerns over Shariah governance and institutional independence.

It concludes that while multiple models support the global growth of Islamic banking, stronger regulatory safeguards are needed to protect Shariah compliance, governance integrity, and stakeholder trust in increasingly complex financial environments.