The Principle of “Trusteeship” in the Governance of Public Assets: A Comparative Study of Iran’s National Development Fund and the UAE’s Abu Dhabi Investment Authority (ADIA)

Tangestani, Mohammad Ghasem; Moradi Berelian, Mahdi

doi:10.22034/lcs.2025.2067790.1158

The Principle of “Trusteeship” in the Governance of Public Assets: A Comparative Study of Iran’s National Development Fund and the UAE’s Abu Dhabi Investment Authority (ADIA)

Articles in Press

Document Type : Original Article

Authors

Mohammad Ghasem Tangestani ¹

Mahdi Moradi Berelian ²

¹ Department of International Law, Faculty of Law and Political Science, Kharazmi University, Tehran, Iran

² Department of Public and International Law, Faculty of Law and Political Science, University of Mazandaran, Babolsar, Iran

10.22034/lcs.2025.2067790.1158

Abstract

The principle of amānah (trusteeship) in Islamic jurisprudence transcends personal morality, functioning instead as a foundational norm for legitimizing the state’s control over public assets. Understood as a divine mandate of fiduciary responsibility, this principle delineates the boundaries of state authority and offers a conceptual anchor for institutional transparency, accountability, and intergenerational justice. This study adopts a comparative-analytical approach to examine the application of this principle in two distinct Islamic legal systems: Iran’s National Development Fund, established under Article 45 of the Constitution with a wilāyat al-faqīh–based interpretation of trusteeship; and the United Arab Emirates’ Abu Dhabi Investment Authority (ADIA), a sovereign wealth fund operating within the framework of an accountable federal monarchy and a vision of strategic generational equity. Through a comparative analysis of legal structures, legitimacy doctrines, oversight institutions, and financial governance mechanisms, the article demonstrates that, while both systems claim a trust-based model for managing public wealth, their divergent theological and political foundations have produced two distinct models of state–citizen–future relations. The findings suggest that a renewed engagement with the Islamic notion of trusteeship can inform the reconfiguration of state financial institutions toward greater accountability, transparency, and legitimacy within Islamic public law.

Keywords

Trusteeship

Public Assets

Islamic Fiscal Governance

Legitimacy

National Development Fund

Subjects