shariah governance in islamic banks and financial institutions in the united kingdom and its comparison with iran

having reviewed the history of the islamic banking development in the united kingdom, this paper tries to evaluate the processes, rules and operational techniques used to regulate and supervise islamic banks and financial institutions in this non-islamic country. in addition, it tries to go over the iranian islamic banking system and compare it with that of england. the results of the paper show that the shairah governance model used in the united kingdom to conduct islamic banking in a country with minimum islamic environment and laws has special and important characteristics. understanding these characteristics may have specific implications for enhancing the shariah supervision in iran. this research emphasizes some of them.