ABSTRACT
The trust vehicle has now become a popular way of channelling funds to charitable or other causes and the chapter suggests that there are common principles permeating trusts in the civil law and common law traditions. At the same time, there is an emergence of inter-governmental trusts that are equally predicated on these principles. The chapter demonstrates that the Islamic trust model (waqf) is not only compatible with its non-Muslim counterparts, but it is also a competitive vehicle that is flexible and capable of producing benevolent outcomes. The chapter outlines the difference of the waqf as compared to its counterparts and suggests that it should be made part of a Hague codification process by which to render it part of the private law of nations.
