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Fatwā and its role in Regulatory Capture and Arbitrage

Joe W. Bradford

Abstract

This paper examines Fatwā in Islamic Insurance and its role as an underlying cause

of Regulatory Capture and Arbitrage. The progression of the Islamic Insurance

industry from one almost unanimously forbidden to a multi-billion dollar industry in

less than three decades is indicative of the notable advances the industry has made.

With its core principles of cooperation, mutuality, and sharing of loss/gain, Islamic

Insurance is of particular appeal to the consumer. The paper highlights the key

obstacles preventing Islamic Insurance from achieving true mutuality and

cooperation, and as such truly serving the consumer for whom it was created. These

obstacles include the conflation of terms in understanding mutuality under an

Islamic rubric, the undue emphasis on the contractual particulars governing the

consumer, and the role of Fatwā or lack thereof in creating Regulatory Capture. It

will cover the need for review of the Islamic legal approaches used in the formation

of Fatwā in order to limit regulatory arbitrage by way of fees and charitable

contributions.

Keywords: Regulation, Capture, Takāful, Insurance, Fatwā

Introduction

Regulatory capture, as defined by Posner, refers to the subversion of regulatory agencies by the

firms they regulate (Posner 2013). Woodrow Wilson is possibly the first to question the

existence of this phenomenon. He says “If the government is to tell big business men how to

run their business, then don’t you see that big business men have to get closer to the government

even than they are now? Don’t you see that they must capture the government, in order not to

be restrained too much by it? Must capture the government? They have already captured it. Are

you going to invite those inside to stay? They don’t have to get there. They are there.” (Wilson

1919).

This line of questioning grew out of the idea that regulated agencies eventually come to

represent the interests of the industries they regulate. Instead of their original mandate they

serve those industries under the guise of protecting the public good. This paper asks if this

question is applicable to Islamic “Takāful” insurance companies. Given that Takāful companies

are setup in a number of regulatory environments, we will look at the one common regulatory

denominator between them all: The Shari’a Board.

Senior Associate, Bank of New York Mellon, Houston TX. Master of Law, Islamic University of Medina,

KSA. Email: Contact@JoeBradford.net.

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“Takāful” Insurance

The progress seen by the Islamic Financial services industry into a multi-billion dollar industry,

coupled with the needs of international business and developing societies, brought about the

need to protect those industries and societies from risk and adverse loss. At its advent, the idea

of utilizing insurance was judged as completely forbidden by Muslim jurists. Although policies

were purchased by Muslim merchants early on, the reaction of Muslim scholars in those times

was to declare such policies to be forbidden (Muslehuddin 1978).

It is interesting to note that while the issue of insurance was debated around the year 1836

CE in the writings of the Ḥanafi Jurist Ibn ʿĀbideen, a push for an “Islamic alternative” to the

seemingly impermissible industry did not arise until much later. Takāful arose as one of these

“alternatives,” a method by which Muslims could advert risk while remaining true to the

precepts of their sacred laws.

Fatwā – Religious Edicts

Fatwā, a religious edict issued by a qualified scholar (a “Mufti”) versed in sacred texts and the

precedents of religious law, is the instrument used to contextualize issues presented to the

Muslim community. The Mufti with regards to God is like a translator with regards to the judge.

He coveys to those around him what he understands from the Judge’s ruling (Gomaa 2009).

Language is interpretative, and following this analogy, the rulings of the judge are as well. That

said, any given Fatwā can only be approximate, never exact. Given the interpretative nature of

law, the role of Fatwā in promoting Takāful cannot be downplayed.

Numerous Fatāwa were issued to declare Takāful permissible, and along with that

conventional insurance as impermissible or Ḥarām. Most of these initial Fatwā are extremely

vague and general, allowing Takāful and encouraging “cooperation and mutual assistance”

while conventional insurance was said to be impermissible because it contains Gharar,

usurpation (akl amwāl ʾl-nās bil-bāṭil), and Ribā. Presented side by side, the choice given to

the religiously conscious Muslim is clear. One can either follow the Fatwā presenting an

acceptable alternative or contravene the sacred texts he claims to belief in and uphold. Only a

slim minority, presented by the scholar Mustafa Zarka, allowed conventional insurance. Zarka

saw no difference between the structure and purpose of conventional and Takāful insurance

(Zarka 1994).

Given that the majority allowed only Takāful without dictating the structures, Shari’a

Boards were formed to dictate how mutual cooperation is implemented. As El-Gamal states, a

superficial notion of mutuality was promoted, one in name not in substance (El-Gamal 2005).

Most Takāful providers are structured with stockholder rather than policyholder ownership.

These shareholders own the company, dictate the vision and approach, appoint the Board of

directors and by proxy the Shari’a Board, and invest the “contributions” made by the

policyholders looking to mutually assist each other. In return for all this, policyholders agree

at signup to give 50% of their contributions to the Takāful Company in exchange for their

service (AbdulHamid 2010).

Takāful Structures

Takāful, an Arabic word connoting mutual cooperation and support, was used to brand this

new industry. In Takāful, a participant (the first party) contributes a particular amount of money

to the Takāful pool, which is then managed by a company (second party) with the understanding

that the second party will assume the legal responsible for unexpected loss (Akhter 2010).

Takāful is marketed as embodying the core principles of cooperation, mutuality, and sharing of

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loss/gain prescribed in the Quran and Sunna (Swartz and Coetzer 2010).

Takāful providers assume legal responsibility to the pay the insurance claims of the

participants. Participants contribute funds to the Takāful pool by way of a voluntary

contribution. Characterized as an amount that is essentially charitable in nature, Takāful thus

saves itself from being commutative in nature. Gharar does not apply to charitable

contributions, and thus the first issue of prohibition is negated. This contribution is then

managed by the Takāful provider. It is invested in various permissible investments, negating

the challenges of Ribā and usurpation (al-Darīr 2004).

Currently there are several broad structures that are used for Takaful. One is the Tabarru’

model, based on a charitable contribution to the insurance company in exchange for coverage.

At times this structure is called a Waqf. The contribution is, in this case, characterized as a

contribution to a charitable endowment. In both cases, those contributions are received for the

benefit of the Takaful policyholders but are not redistributed to them in the case of a surplus,

as they are considered charitable. Charitable contributions may not be clawed back under

Islamic law, and as such are left in the pool. This last point is of particular concern. While the

assumption is that this surplus will be used for reinvestment into the pool, it may be used for

compensation of the fund/pool manager.

This brings us to the next two structures, Muḍāraba and Wakāla. The first is a modified

profit and loss-sharing model used extensively in Islamic finance. While the profit of

underlying investments is shared by the policyholders and the shareholders, there is

considerable concern for how truly “mutual” those profit sharing ratios are, especially in areas

with government mandated insurance lines. By and large the underwriter will share in both the

results of operations as well as surpluses gained through favorable performance. In the Wakāla

structure, the Takaful insurer earns a fee for his service instead of sharing in the underwriting

results, yet may benefit from surpluses gained including but not limited to performance

incentives and fund management fees. (Wong-Fupuy, et al. 2012)

What is noticeable in each of these structures, whether characterized as a social enterprise,

a profit-sharing mechanism, or a fee based service, is the presence of both management

companies directing the underwriting and profit sharing, as well as the presence of government

mandated insurances lines. This would seem to cast considerable doubt on the claims to

mutuality made by Takāful proponents. The ability of management to cancel policies, deny

claims, and raise rates would seem, as shall be mentioned later in this paper, to wholly

transform the nature of the Takāful contract from one that is mutual to one that is commutative.

Why Takāful?

While one may argue that insurance lines are available in both conventional and Takaful

insurance, the choice is not so clear. Studies have shown that despite demand, insurance

penetration is low in Muslim majority populations. (Lester 2011) The dearth of Sharia

compliant products has been cited as a reasons for low insurance penetration (Keller and Suter

n.d.) despite insurance products having been offered for a extended period of time.

Lines of insurance are steadily increasing in these areas, and Takaful has been anchored in

place by the growth of government mandated insurance lines such as health, auto, and workers

compensation insurance. (MENA Review 2012) The development of the insurance industry in

Muslim Majority areas, specifically the MENA region and Malaysia, is highly affected by both

cultural and religious factors. (Keller and Suter n.d.) In areas where religious scholars affect

public sentiment, the role of the fatwa cannot be denied in turning people towards or away from

a particular product offered.

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Obstacles to Mutuality

Perhaps the most glaring obstacle to mutuality in Takāful is the prevalence of the Takāful

structure itself. Although characterized as based on mutual cooperation and assistance, the

presence of shareholders who own the company or have a significant controlling interest in the

direction of the company is problematic to say the least. Despite the claims of mutuality the

fact that the policyholder, in order to insure against loss, must agree to exorbitant amounts of

his contribution (in some cases => 50%) being given to the company in the form of fees would

seem to negate any notion that this contribution is “voluntary” in any way, shape or form.

Because coverage will not be provided unless a contribution is made, and will be revoked when

a contribution is missed, shows that the fundamental relationship that the Takāful Company is

based on is in fact commutative and not mutual. Had it been mutual, than shortfalls and

inabilities to contribute to the pool would have been considered a covered loss.

Takāful companies, while presented as being based on Islamic principles, and at times

claimed to draw from the same actuarial and management methods used by western mutual

insurance companies, are in fact more similar to Mutual Holding companies than either of the

aforementioned structures. It can be said that Takāful is actually closer to being a type of Mutual

Holding Company. Created from the outset for the benefit of the shareholders albeit with a

“mutual” component, instead of being mutual from the outset and then going through

demutualization. Mutual Holding companies have been characterized as "legalized theft" and

“a shell game” and a “bait and switch” (Rambeck 2001). While giving the Takāful contributor

the illusion of cooperation with like minded people, in reality they are left only with policies

that are only half as effective as they could be (because 50% of the contribution goes to the

company) along with coverage along with no decision making power or ownership stake in the

company.

While the structure of choice does not seem to be of much concern to the average business

person, it does have an affect on the contractual relationship between the policyholder and the

company. This relationship is complicated even more, when Fatwā is used to promote it as the

only permissible option available to a religiously minded Muslim.

Fatwā Redux

The problems found in the Takāful structure are largely a result of the Fatāwa issued about

insurance in general. Fatāwa that prohibit commercial insurance and represent Takāful as only

permissible option, effectively cut the choices of any consumer in half. The fact that Takāful

structures are approved by Shari’a Boards appointed by the Shareholders of the Takāful

Company presents a possible conflict of interest on the part of those scholars. This conflict of

interest is exacerbated when those scholars paid in the form of stipends and bonuses, similar to

commission based services instead of fee-based ones.

This seemingly simplistic approach to dealing with the need for insurance is due, in large

part, to the methodology used to prohibit conventional insurance and create alternatives. As

mentioned earlier, conventional insurance was deemed impermissible due to the presence of

three things: Gharar, usurpation (akl amwāl ʾl-nās bil-bāṭil), and Ribā. Mustafa Zarka,

presenting the only dissenting opinion to this early Fatwā, was not convinced of the presence

or effectiveness of these issues in insurance. The latter two, he said, are not part and parcel of

the insurance contract but are consequences of its investment and management strategies and

therefore should on be taken into consideration, as they may be sidestepped. The issue of

Gharar for him was an actuarial issue, in which through the law of large numbers the

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uncertainty of risk is greatly diminished by the large number of policies issued. The presence

of unknown elements in a contract, he opines, will only invalidate a contract when they are the

dominant element, not when they are negligible or highly diminished in nature (Zarka 1994).

So while an insurer would have to pay an exorbitant amount to compensate a single

policyholder’s losses (if he were the only policyholder) would not face the same risk when

holding the policies of hundreds or thousands of insurance policy holders. This position can be

likened to the consensus claimed by the classical scholar al-Nawawi, who stated that scholars

are in agreement that it is permissible to charge one to drink from a water skin even though the

amount customarily drank is unknown and unquantifiable (al-Nawawi 1972). Thus while

compensation paid to an individual policyholder would seem to be unquantifiable and thus

Gharar, through the use of actuarial sciences one can ascertain the median amount needed to

be able to fulfill the contract. One thing the opinion of Zarka does not consider however, are

the payouts to the insured. While Gharar may be diminished for the insurer, it may very well

not be the same for the policyholder. This is because Gharar in insurance is not wholly

analogous to the water skin example above. The policyholder, far from consuming a readily

available product, does not parity between premiums paid and return on those premiums, which

may be minimal. This in and of itself has not been sufficiently analyzed, and is present in both

conventional and Takāful insurance schemes.

Critics of Zarka’s approach rebutted that while all of this may be true, it is impermissible

to contract for the compensation of loss, as such a thing is not found in the corpus of Islamic

law (al-Darīr 2004). Zarka’s retort to this is that compensation is not the object of the contract

but instead it is the security that one attains from knowing that he can be compensated. He

likens this to the security attained from hiring a security guard. While that security guard may

never need to physically intervene for the safety of his employer or his employers property, he

is still due compensation for his diligence in providing safety and security for his employer and

acting as a deterrent to theft and robbery. It may be added as well that the absence of an issue

or contract from the corpus of Islamic law is not sufficient to label that contract as invalid or

forbidden. The idea that the corpus of Islamic law is all inclusive of God’s Sharīʿa is not only

problematic in an epistemological sense, but causes an undue emphasis on the particulars of

the insurance contract without regard for its novel nature and the needs that it meets.

UNDUE EMPHASIS ON CONTRACTUAL PARTICULARS

Presenting security and safety as impermissible to contract for due to their absence from the

corpus of the Islamic legal texts is an issue of approach. It is of considerable use in modern

Fatwā, particularly when speaking about new forms of contract. While more prevalent in the

Islamic financial services, the use of this so called absence as a ratio legis for prohibiting

insurance is problematic in two ways. It presents Islamic law as a system dependent upon

medieval contract forms in order to be permissible. This no doubt stifles creativity and causes

the use of artifice to become prevalent in hopes of making these medieval forms fit the needs

of a modern economy. Secondly, in terms of legal theory, it reflects a basic lack of

understanding of the permissibility of trade explicitly mentioned in the Quran which most

scholars both pre-modern and modern claim to ascribe to.

The verse of Quran in question is found in 2:275 “God has permitted trade and forbidden

Ribā.” The vast majority of scholars past and present will say that the meaning of this verse is

general (Arabic: ʿĀm), i.e. God has permitted all forms of trade. This generality, according to

the universally accepted rules of Usūl al-Fiqh, cannot be made specific except by a specific

text limiting this general allowance (al-Qurṭubi 1964). So, for example, the Prophet came to

Medina and found the people using a type of per-Islamic form of forward sale to sell fruit. He

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specified the boundaries in which they can sell fruit through a forward sale, namely that the

quantities and qualities of the yield must be specific in the contract as to avoid dispute at harvest

and delivery time. Therefore the general permissibility of trade stands, but is specified in terms

of the quantity and quality of the object of sale. Another explanation of this verse exists. The

Andalusian scholar of Islamic law, Ibn Ḥazm, held that this verse is not general. He claimed

that this verse was ambiguous (Arabic: Mujmal), and as such needed an explanatory text

(Arabic: Mubayyan) to clarify what sort of trade is permissible and what is not. He claimed to

have substantiated all forms of trade known at the time of the Prophet with a text from the

Sunna, except for one. All forms of trade then must fit into one of those found in the Islamic

texts, all others being impermissible (Ibn Hazm 1933).

Fatwā (or lack thereof) and Regulatory Capture

The claim that security or safety is not a valid object of contract would, at face value, seem to

agree with the minority opinion of how contract is to be formed (that of Ibn Ḥazm mentioned

above). The opinion of the majority is functionally disregarded even by those that claim to

uphold the meaning of the verse as general. It restricts the ability of the market to freely contract

and innovate financially. This approach effectively allows Takāful companies (by proxy

through their Shari’a boards) to claim exclusive right to insure the consumer. Since contract

must be substantiated in medieval texts outlining God’s laws, and the “translators” of such laws

are the Muftis on the Shari’a boards, consumers must follow these Fatāwa or otherwise they

will be sinful. In essence what has happened is the Fatwā now, more than just a marketing

device, has allow the industry to capture a significant segment (if not a majority) of the

population by two means: the enforcement of insurance coverage for basic needs (such as car

insurance), and the elimination of competition not endorsed by Shari’a Boards. An added

dimension to this is the elimination of Shari’a competition by the industry. Scholars are chosen

to serve on boards due to the conclusions they make, not the objectivity of their opinion. While

difficult to claim direct causation, the fact that the top 10 Shari’a Scholars involved in Islamic

Finance hold 450 out of 1141 board positions that are available and represent 39.44% of the

universe is cause for alarm (Unal 2011).

Faced with diminishing choices, the consumer can do one of two things. She can choose to

break the law and not insure, or she can choose to follow the law of the land and “God’s law”

by “contributing” to an Islamically acceptable insurance company. If in fact Takāful was

charitable and voluntary then the policyholder is essentially donating his money to others in

return for something with is uncertain. The Takāful policyholder is giving away a portion of

his wealth in hopes to receive compensation in the face of future losses. There is no expectation

of receiving the principle contribution. In essence, for the consumer, the effect of the Takāful

insurance and conventional insurance is one and the same.

Fatwā dealing with conventional insurance

If, as Da Vinci said, “nothing strengthens authority as much as silence” then silence on the

issue of how individual consumers navigate the entirety of the insurance market truly is nascent

approval or acceptance of the “Islamic” portion. After reviewing the Fatwā specific to the

insurance industry, the majority of these Fatāwa deal with the issue of insurance from the

viewpoint of the insured. Critique of the insurance industry, regulation of it as a whole, and the

need for equitable pricing is almost absent. This one-sided approach to insurance ignores the

need for equitable and fair regulation of the insurance industry. Another major problem that

arises is the marginalization of the judiciary. Whether or not a contract is permissible and

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enforceable under law should be the sole domain of the judiciary when disputes arise. By

preemptively approving and disproving contracts, an entire branch of government is

circumvented.

If this is the case, there would seem to be no difference between commercial and mutual

insurance; in both you will end up receiving the same compensation and in both you will pay

a similar amount. What does seem to be of consequence is the use of that money by the

insurance company, their ability to cancel the policies of their clients, and their secondary

investment of that money for their own profit. If the insurance companies are characterized as

Waqf, how can a beneficiary in need be excluded from the policy if he fits the needs for which

the Waqf was created? If a Tabarruʿ, then how can a charitable contribution be given in

exchange for coverage? Would that not be commutative and not mutual? If characterized as a

Muḍāraba, then how can a business partner be forced out of a partnership without being made

whole? If a Wakāla, then how can an agent dictate to the principal how and what his relationship

will be, forcing the principal out of the contract without making him whole?

If, as previously mentioned, the effects of holding a policy are the same regardless of

whether that policy is provided by a Takāful company or a conventional insurance company,

then the body of Fatwā should be focused on changing the regulatory environment in which

insurance companies operate. The permissibility of insurance (or lack thereof) would seem to

lie in regulation of the industry itself, not in the character of the end-user agreement.

This insistence of addressing consumer issues and not larger regulatory issues, is indicative

of Fatwā being used to force upon the population a certain form of mutually beneficial

compensation (to the providers, the boards, and the regulators) while disregarding the general

welfare of the same population.

Why Contract Form shouldn’t matter (to the consumer)

Consumers are, in fulfilling that which God wants of them, wholly reliant two things: their

intellect and the experts they can consult. If the experts they can consult are comprised or have

a conflict of interest then asking them about insurance would seem to be a moot point. The

question remains as to how a seemingly impermissible transaction may be entered into while a

“permissible alternative” exists? This of course, is under the assumption that the sovereign

government which regulates the insurance industry also claims to base its laws on the general

principles of the Shari’a. If this is the case, then the judiciary of that state should decide whether

or not a particular contract is acceptable under the Shari’a or not.

When looking back to the corpus of Islamic law that the same scholars who prohibit

conventional insurance draw from, we can find several precedents for allowing a consumer to

shop the market place without being blameworthy for the actions of the counterparty. In silent

partnerships (Muḍāraba), partners are to share equally in the profit and loss of the partnership.

If say, the silent partner specifies for himself some form of profit to the exclusion of the other,

how are profits distributed? This sort of condition is forbidden, and the deal is labeled as corrupt

partnership (Muḍāraba Fāsida). Some said that this partner should be given salary

commensurate to his work. Others said that he should receive the profit commensurate to that

which a partner similar to him would receive. The point here being that the invalidity of one

party to the contract did not invalidate that contract as a whole. In instances in which the

counterparty is powerful or informed enough to adversely affect the validity of the transaction,

it is incumbent on the sovereign to enact laws that protect consumers (al-Mawardi 1989). Just

as the state should guarantee fair business practice and fair compensation, it should regulate

the insurance industry accordingly.

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While it could be said that one should not knowingly contract with a party if they are known

to do things which invalidate the contract it can be said that conventional insurance, without a

clear ruling from a higher court, cannot be deemed unequivocally impermissible In fact,

Muslim scholars have stipulated that mere doubt in a transaction in one persons estimate is not

sufficient for declaring that transaction invalid or impermissible. For this to be done, the

sovereign must enact a law stating such. The Islamic legal maxim “A sovereign’s ruling

removes variance of opinion” (al-Zarkashi 1985) would be applicable here and would be

decisive. While this maxim is often thought to apply solely to the Judge (Qāḍī), there is

sufficient evidence to show that it is applicable as well to statutory law based on protecting the

public interest and is enforced by the sovereign ruler. (al-Mazrūʿ 2012)

Additionally, jurists have discussed hypothesized on what a businessperson is to do in the

situation when all market choices are doubtful. Must he abstain for fear of falling into the

Ḥarām, or may he transact based on the principle that business is permitted until there is surety

that Ḥarām exists? (al-Suyuti 1990) While most jurist opined that engaging in business may be

disliked due to a possible Ḥarām element being present, they did not proscribe business in this

situation completely. If we were to take into consideration mandated insurance lines in many

markets, the idea of anything being disliked would be non-existent, leaving only the base

permissibility to contract business (meaning here: getting an insurance policy) without

culpability or guilt for doing what is Ḥarām on the part of the consumer.

To these ends, it shouldn’t matter then to the end-user as to what type of insurance he buys,

to what extent he insures his property, and to what extent he receives compensation for his

losses. Regardless of whether or not he used Takāful insurance or conventional insurance, with

both he will receive compensation commensurate to his losses. The real question should be in

this case: but will the Insurer receive compensation commensurate to his effort? I suspect that

in both commercial and Takāful structures some form of price gouging happens.

Conclusion

As pointed out by Posner, “as a rule, regulation is acquired by the industry and is designed

and operated primarily for its benefit.” (Stigler 1971) The fact that conventional insurance is

excluded from the market by way of Fatwā means that conventional providers have three

choices: serve a niche market looking for their services, transform into a Takāful provider to

maintain market share, or close its doors. None of these three conclusions address the problem

inherently found in Takāful structures, nor do they address the regulatory issues and the need

to promote fair and equitable business practices. In fact, they encourage collusion between

insurance providers and the regulators (the Shari’a boards and regulatory bodies) allowing for

application of industry preference without legislative or judicial review. In essence, the

Islamization of the industry weakens not only the consumer, but also the state that represents

him. This allows the industry to be captured by Fatwā, and Fatwā to be captured by big

business. What is needed is not more Islamization, but better use of Islamic Law to create

equitable, just, and fair markets for all stakeholders.

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Endnotes

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wa Sanadiq 'l-Takaful." Multaqa al-Tameen al-Ta'awuni. Riyadh: Muslim World

League.

3. Akhter, Waheed. 2010. "Risk Management in Takaful ." Enterprise Risk Management

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4. al-Darīr, al-Saddiq. 2004. "al-ʿItbārāt al-Sharʿiyya li Mumārasat ʾl-Tʾamīn."

Khartoum: Nadwat 'l-Tamin 'l-Takafuli.

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6. al-Mazrūʿ, Abdullah. 2012. Ilzām wali al-ʾAmr wa Atharuhu fi al-masāʾil al-

khilāfiyya. Riyadh: alBayan.

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10. al-Zarkashi, Muhammad b. Bahadir. 1985. al-Manthur fi 'l-Qawa'id. Kuwait City:

MInistry of Religious Affairs.

11. El-Gamal, Mahmoud Amin. 2005. "Mutuality as an Antidote to Rent-Seeking Shari`a-

Arbitrage in Islamic Finance." Mahmoud Amin El-Gamal - Rice University. April.

Accessed October 6, 2013. http://www.ruf.rice.edu/~elgamal/files/Mutuality.pdf.

12. Gomaa, Ali. 2009. "al-Iftā: ḥaqīqatuhu wa ādābuhu wa marāḥiluhu." al-Mu'tamar al-

'Alami lil-Fatwa wa Dawabituha. Makka: Muslim World League. 29.

13. Ibn Hazm, Muhammad. 1933. al-Muhalla bil Athar. Cairo: al-Matba'a al-Muniriyya.

14. Keller, Benno, and Roy Suter. n.d. The role of insurance in the Middle East and North

Africa. paper, Zurich: Government and Industry Affairs unit of Zurich Insurance

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http://www.zurich.com/internet/main/sitecollectiondocuments/insight/the-role-of-

insurance-in-middle-east-north-africa-en.pdf.

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