Use casesFinancial institutions & fintech

  • Participation bank

Participation banking compliance review

Every murabaha sale, lease, and pool transaction in the sample has to fit the advisory committee's decisions, and the proof sits in five systems.

With the systemEach sampled transaction gathered, every clause read against the committee's decisions, dates checked; a person decides.

Who decides
Participation compliance officer

e-Invoice archive · supplier invoice · 14 October 2026

e-Invoice · CNC lathe, one unit

Buyer: K*** Katılım Bankası A.Ş. · Delivery to: the customer's workshop, as the bank's agent. Invoice date: 14.10.2026.

→ two days after the murabaha sale, 12.10 · to the committee

Illustrative The document as it arrives. In red, what the system marks for your expert.

1. The work

Today

  1. GatherEach quarter the participation compliance unit samples murabaha sales, leases (icara), and profit-sharing pool transactions, and reviews new products and contract templates before they reach the advisory committee; for each sampled transaction a specialist pulls the purchase promise, the supplier invoice, the delivery record, the sale contract, and the payment to the supplier, screen by screen.
  2. ReadThey read every clause against the advisory committee's decisions and the participation standards: who bought the goods and when, whether the customer acted as the bank's purchasing agent (vekâlet), how the profit and the price were set, and what the late-payment clause says.
  3. CheckDates and amounts are compared by hand: the bank's purchase and the supplier invoice before the sale contract, the price fixed when the contract was signed, the supplier paid by the bank and not by the customer.
  4. DecideThe compliance officer writes each finding into the quarterly report, raises any non-compliance so the transaction is stopped and a remediation plan is made, and puts questions of interpretation to the advisory committee.

With the system

  1. GatherThe agent runs the evidence checks in parallel, read-only, across core banking, the e-invoice archive, document management, and payments, and assembles one file per sampled transaction, each document cited.Agentic AI
  2. ReadThe SLM reads the contracts, invoices, and delivery notes against the committee's current decisions and the standards, retrieved at the time of reading, and cites the decision or standard clause behind each point; questions of interpretation are marked for the committee.SLM
  3. CheckYour written checks, run as code, compare the dates and amounts: purchase and invoice before the sale, the price fixed at signing, the payment to the supplier made by the bank.Your rule
  4. DecideThe participation compliance officer reads the file and decides each finding, as before; whether a product, contract, or transaction conforms stays the advisory committee's decision.Person decides

What lands on the desk

The compliance officer gets every document of the transaction in one file, each clause read against the decision or standard it rests on, and the dates checked by your own rules. The file names the one point that needs the committee and never says whether the transaction conforms.

FIG. 1 · Compliance check fileIllustrative
Murabaha · quarterly sample · Q3 2026SME, metal parts · CNC lathe purchase

Agent · documents gathered

  • PromiseCustomer's purchase promise, signed 08.10.2026document management
  • SaleMurabaha sale contract, signed 12.10.2026core banking
  • InvoiceSupplier e-invoice to the bank, dated 14.10.2026e-invoice archive
  • PaymentBank paid the supplier directlypayments

SLM · clauses against decisions and standards

  • metCustomer acted as the bank's purchasing agent; agency letter on fileMurabaha Standard 2.8.1
  • metProfit stated to the customer in the sale contractMurabaha Standard 2.5.5
  • metLate-payment clause in the committee's approved wordingcommittee decision

Code · dates and amounts

  • flaggedSupplier invoice dated after the sale contracttwo days later
  • metSale price fixed at signing, not tied to an index
  • metSupplier paid by the bank

SLM · for the officer and the committee

The bank's purchase must come before the final sale (Murabaha Standard 2.5.1). A pro forma invoice dated 09.10 is on file; whether it shows the purchase was made before the sale is a question of interpretation, marked for the advisory committee.

  • SLM
  • Agent
  • Code

Why a person decidesThe finding is the compliance officer's; whether the transaction conforms is the advisory committee's.

DecidesParticipation compliance officer

2. The system

For your technical team — skip it if you like.

How it works

In

  • The sampled transaction or contract template
  • Core banking and payment records
  • The e-invoice archive
  • Document management (orders, deliveries)

  1. Agent · acts

    Transaction file agent

    Parallel evidence checks; read-only

    Reads

    • Everything under In

    Out

    • Purchase promise and sale contract
    • Supplier invoice and delivery record
    • Payment to the supplier and agency letter
    • One file, each document cited

  2. SLM · reasons

    Contract and decision reader

    SLM, with retrieval over the committee's decisions and standards

    Reads

    • The transaction file
    • The committee's current decisions
    • The standards and approved templates

    Out

    • Each clause against the decision it rests on
    • Dates, parties, and goods pulled
    • Questions of interpretation marked

  3. Code · calculates

    Date and amount checks

    Your written checks, run as code; no model

    Reads

    • Purchase, invoice, and sale dates
    • Price, profit, and payment records

    Out

    • Purchase and invoice before the sale
    • Price fixed at signing
    • Supplier paid by the bank

  4. Decision

    Participation compliance officer

    Reads

    • The file and its citations

    Out

    • Decides each finding
    • Raises any non-compliance for stop and remediation
    • Puts interpretation questions to the committee
How the agent's work is arrangedParallel

Parallel

The evidence for one transaction sits in independent systems and every file needs all of it, so the checks run side by side and merge into one file.

How the models are trained and tested

Your expert writes the test first. A step the test does not need is skipped, and we say why.

Show the training steps

Small language model (SLM)

  1. Test set

    200–400 past sampled transactions and contract reviews with your compliance unit's findings, graded by your senior participation compliance specialists, each finding labeled with its clause and the decision it rests on.

  2. Dataset

    Past files and findings, the committee's decisions, and your approved contract templates; customer data masked in training copies where the test allows.

  3. Continued pre-training (CPT)If needed

    Only if the base model fails the test on participation finance terms (murabaha, icara, kabz, vekâlet, müşâreke).

  4. Supervised fine-tuning (SFT)

    On reading your contracts and invoices and on your finding format, each point tied to its source.

  5. Reinforcement learning (RL)Skipped

    Skipped: reading and citing are taught by fine-tuning, and no further reward is needed.

  6. Retrieval

    Retrieval supplies the committee's decisions, the participation standards, and your templates as they stand today; the model never holds them in its weights, and it never decides conformity.

  7. Monitoring

    The compliance officer reviews every file; a finding the committee or internal audit changes joins the next test.

Where the agentic system stops

The participation compliance officer decides each finding and reports it; any non-compliance goes to the process your board has set to stop the transaction, inform the advisory committee, and plan the remedy.

Show its tools, limits, and record
Tools and access
Reads core banking, the e-invoice archive, document management, payments, and the customer and supplier records; read-only; writes only the transaction file.
May not
Say that a product, contract, or transaction conforms to participation principles, issue any opinion in the committee's name, stop or change a transaction, edit a contract or template, contact the customer or the supplier, or grant itself any access.
Who decides and the written limit
Participation compliance officerThe participation compliance officer decides each finding and reports it; any non-compliance goes to the process your board has set to stop the transaction, inform the advisory committee, and plan the remedy. Whether a product, contract, or transaction conforms to participation principles is the advisory committee's decision alone. The system never gives that opinion, never stops or changes a transaction, and never edits a contract.
Stops when
A document is missing or unreadable, the supplier and the customer look related, a clause matches no decision the committee has taken, or a decision has changed since the sample was drawn: the file goes to the compliance officer, marked.
Record
Every document and system read, each check and the decision or standard clause behind it, the rule versions, the file, and who decided each finding and when.

How agentic systems stay inside limits

3. Value and conditions

Where the time goes, and what your institution will measure.

Where the value comes from

  1. More of the quarterly sample read in full.
  2. Every finding tied to the decision or standard it rests on.
  3. Questions for the committee sent with the evidence attached.

What your institution measures

  • Transactions reviewed per specialist per quarter
  • Time from sample to finding
  • Findings the committee or internal audit later changes
  • Repeat findings on the same product

Measured in the Decision Blueprint

Today's transactions reviewed per specialist and time from sample to finding, from your last quarterly report, set the baseline; your institution sets the target.

Conditions

The rules, the data, and the known error, with its guard.

  • Under the Katılım Esaslarına Uyum Tebliği (BDDK, Resmî Gazete 19 December 2025, no. 33112), the bank's advisory committee alone decides on participation principles and signs off standard contracts (art. 8); the compliance function checks products, contracts, and transactions against those principles and the committee's decisions and reports at least every three months (art. 10). The system prepares the check and never gives the committee's opinion.
  • The published Murabaha Standard (TKBB standard no. 3, 6 May 2021) requires the bank to have bought the goods and taken real or constructive possession before the final sale (2.5.1), the sale contract to follow the purchase (2.5.3), and the price to be fixed when the contract is made (2.5.6); these run as code only in the rule wording your committee signs off.
  • When non-compliance is found, the board answers for stopping the transaction, informing the advisory committee, and preparing a plan to remove it (Tebliğ art. 14); the system marks the point, and a person raises it.
  • No machine-learning model is needed: what a transaction must meet is written in the decisions and the standards. Decisions change, so retrieval reads the current text each time.

Start here

We take one quarter's sample with your compliance unit, time each step from sample to finding, collect the committee's decisions and your templates, and test the reader on your own contracts and invoices before anything is built.

Who builds it Every engagement is led by an engineer who has built machine-learning models that real decisions run on since 2012, and language models and agentic systems in production since 2024. About eqlx

Request a Decision BlueprintWhat the Decision Blueprint covers

Equalize the gap.

Bring work that takes expertise. Leave knowing the first step.

A short description of the work is enough; no confidential records.

  1. You send a short descriptionNo confidential records, credentials, or production data
  2. The engineer checks whether it fits, and what it would needA model, a small language model, an agent, or none
  3. A proposed first step, or an honest “not a fit”A technical conversation with the engineer
Start with a Decision BlueprintTalk to the engineer

https://eqlx.ai/use-cases/participation-compliance · Printed copy; the website is the current version.