This article provides a comparative analysis of national Islamic finance models with particular emphasis on the institutional experience of the Gulf Cooperation Council countries and Southeast Asia. The study examines the structural features of Islamic finance markets, the dominance of debt-based instruments such as Murabaha and Ijarah, the role of Sukuk in capital market development, and the limited application of profit-and-loss-sharing contracts such as Musharakah and Mudarabah. Special attention is paid to the institutional differences between Malaysia’s centralized regulatory model and the more decentralized Shariah governance practices historically observed in the Gulf countries. The article argues that for Uzbekistan, direct replication of the Gulf model would not be fully appropriate due to the country’s secular legal framework and the existing dominance of conventional banking.