Practice focus
AAH Oceans advises family offices and private capital across the GCC on structuring wealth, investments and succession in accordance with Sharia principles — combining Islamic finance structuring with the discipline of twenty-five years of international transactional practice in the energy sector.
All Sharia advisory is delivered in coordination with recognised Sharia scholars and supervisory boards; AAH Oceans provides the legal architecture that gives their determinations contractual force across jurisdictions.
Structuring intergenerational wealth transfer in alignment with Faraid inheritance principles, using DIFC and ADGM foundations, registered wills and holding structures to deliver certainty across common law and civil law jurisdictions.
Design and documentation of Musharakah, Mudarabah, Ijarah and Murabaha structures for direct investments, real estate and private equity participations.
Advisory on Sukuk issuance and Istisna'a-based construction and energy asset financing — drawing on direct EPC contracting experience across the GCC's major capital programmes.
Portfolio screening frameworks, income purification protocols and ongoing compliance governance, including liaison with Sharia supervisory boards and standard-setting bodies.
Structuring charitable and family endowments (Waqf) with governance frameworks that preserve the founder's intent across generations and jurisdictions.
Policies and calculation frameworks for Zakat across complex, multi-asset holdings, integrated with the family office's wider reporting and distribution arrangements.
Illustrative of the nature and complexity of engagements undertaken. Details are anonymised and, where indicated, composite in character to preserve client confidentiality.
Islamic Project Finance
Advised a GCC family office on the Sharia-compliant financing of a midstream energy asset, structuring the construction phase through Istisna'a with forward lease (Ijarah Mawsufah fi al-Dhimmah) upon completion — preserving compliance without sacrificing bankability.
Succession Planning
Structured a multi-jurisdictional succession plan for a Gulf family with UK and UAE assets, combining a DIFC foundation with English law arrangements to reconcile Faraid distribution principles with common law certainty.
Portfolio Compliance
Conducted a Sharia compliance review of a family office's direct investment portfolio, restructuring conventional debt positions into Murabaha facilities and implementing an ongoing screening and purification framework.
Sharia compliance most often fails not on doctrine but on enforceability — structures that satisfy the scholars yet collapse in a secular courtroom. Effective structuring must hold in both.
The English Court of Appeal confirmed that Sharia, not being the law of a country, cannot operate as the governing law of a contract. A clause providing for Sharia principles is ineffective, and the contract falls to be construed under national law alone — leaving parties who relied on it unprotected.
The structuring answer: incorporate specific AAOIFI standards as express contractual terms under English or DIFC law, so that compliance is enforced as a matter of contract rather than left to an inoperative choice-of-law clause.
Dana Gas sought to have its own US$700 million sukuk declared unlawful and unenforceable on the ground that the structure was no longer Sharia-compliant — an attempt to deploy religious compliance as an escape from commercial obligations, triggering litigation across the UAE and English courts.
The structuring answer: waiver-of-Sharia-defence clauses, obligor representations that the structure is compliant at signing, and English law purchase undertakings drafted to survive any subsequent compliance challenge — now essential protections in any well-structured issuance.
A Faraid-compliant will over English assets is exposed to challenge under the Inheritance (Provision for Family and Dependants) Act 1975, under which a spouse or child may claim that fixed Sharia shares fail to make reasonable provision. The conflict cannot be drafted away within the will itself.
The structuring answer: lifetime structuring — transfers into DIFC foundations or family investment companies during the founder's lifetime — achieves Faraid-aligned distribution while leaving no estate on which a statutory claim can bite, satisfying both systems without offending either.
AAH Oceans Consultancy provides legal and strategic advisory services. It does not issue Sharia pronouncements (fatawa); determinations of Sharia compliance rest with the appointed Sharia scholars or supervisory board on each engagement.
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