digiwaqf — Legal Document Package
Working first drafts for counsel and Shariah review. English. Not legal advice, not an offer of securities.
Entities. EVA DAVA EOOD (Bulgaria, VAT BG207945177) — existing company, temporary administrator of three money flows; U21C — Ummah 21st Century — future technology/management company (DIFC); the Waqf — future perpetual endowment (Labuan).
Naming. The company is Ummah 21st Century, short form U21C. Drafts of this package written on 2026-07-14 used "EU21C" throughout; that was a drift with no source and is corrected here. If you hold an older copy, U21C and EU21C are the same entity.
Three flows (never commingled).
- SAFE investments → future equity in U21C (commercial).
- Platform donations → build the platform (irrevocable charity, no financial rights).
- Future Waqf donations → seed Waqf corpus (held temporarily, ⛔ gated on fatwa).
Dispute resolution. Investor/commercial docs → DIFC law + DIAC arbitration (seat DIFC, English) + Shariah referral. EU consumer donation docs → Bulgarian/EU law + courts (arbitration is not imposed on consumers). See doc 00.
Phase 0 — open the SAFE round + platform (no fatwa required) ✅ drafted
| Doc | Title | Flow |
|---|---|---|
| 00 | Governing Law & Dispute Resolution (master clause) | all |
| 01 | SAFE Agreement | 1 |
| 02 | SAFE Registry (structure) | 1 |
| 03 | EVA DAVA — Administrator Resolution, Segregated Accounting, Amanah | all |
| 04 | Platform Donation Terms | 2 |
| 04b | Future Waqf Donation Terms (⛔ inactive until fatwa) | 3 |
| 05 | Investor Qualification, KYC & AML Policy | 1 |
| 06 | Risk Disclosure | 1 |
| 07 | Proof of Payment / Subscription Confirmation | 1 |
Also live: Privacy Policy (/privacy) · public Terms (/terms) — to be aligned with 04.
Phase 1 — Shariah & governance ✅ drafted
| Doc | Title | Note |
|---|---|---|
| 08 | Shariah Governance Charter — SSB & Sharia Investment Committee | SSB has veto + gates; SIC mixed competence, halal veto |
| 09 | Fatwa Request — Shariah brief to the Board | ⛔ the gate — 34 questions (A–I) |
| 10 | Negative Screen Policy | applicants + corpus (AAOIFI ratios, purification) |
| 11 | Grant & Qard Hasan Policy | Type A Hibah / Type B Qard Hasan; yield only, corpus never spent |
| 12 | Success Sadaqah Framework | must be voluntary & unenforceable — else riba |
| 13 | Voting Rules (advisory) | community filters, committee decides |
The two briefs — both gate launch
| Doc | Goes to | Gates |
|---|---|---|
| 09 | SSB (Mufti Ismail Desai) | ⛔ Flow 3 · payment for waqf contributions · establishing the Waqf · Hibah/Qard Hasan + Success Sadaqah instruments · the status & vote mechanic (§G, Q23–31) |
| 14 | 3 counsel tracks (BG · DIFC · Labuan) | 🔴 Flow 2 and the SAFE round should not open until §A (licensing / insolvency), §B (donor KYC) and §E (consumer law) clear |
Neither brief has been sent. Flow 2 and the SAFE round do not require the fatwa — but they do require the 🔴 sections of doc 14.
Phase 2 — Waqf establishment (Labuan) ⬜
Labuan waqf foundation charter/deed + registration · Investment Policy Statement (sukuk / Islamic ETFs, ~6–8% indicative) · broker/adviser mandate (license-light).
Phase 3 — U21C incorporation (DIFC) ⬜
Incorporation · shareholders' agreement · SAFE conversion mechanics · Management / Advisory / Technology services agreements (U21C ↔ Waqf).
Review gates
Each track gets the documents plus its slice of doc 14 — the sections are self-contained and meant to be split.
- Bulgarian corporate + consumer + AML counsel → 03, 04, 04b, 05, 13 · doc 14 §A–G.
- DIFC / corporate counsel → 00, 01, 02, 06, 07, Phase 3 · doc 14 §H.
- Shariah Supervisory Board (Mufti Ismail Desai) + Islamic-finance adviser (Vladimir Malenko) → 01 (equity form), 04b, and all of Phase 1 · doc 09.
- Labuan counsel / trust company → Phase 2 · doc 14 §I.
Two questions are deliberately asked of both sides, because the answers must agree: cross-flow entitlement (09 Q29 ↔ 14 §C15) and the fee/carry structure (09 Q10 ↔ 14 §H39).
Published in full and on purpose. These are working drafts, not executed documents and not legal advice. They describe a pre-launch project: digiwaqf is not yet a licensed waqf and is not Shariah-certified. Nothing here is an offer to sell securities.
