COMPARATIVE ANALYSIS OF SOVEREIGN FUND MODELS: NORWAY, SINGAPORE, KAZAKHSTAN AND AZERBAIJAN — IMPLICATIONS FOR UZBEKISTAN

Abstract

Sovereign funds are discussed as a single institutional category, yet the four cases examined here — Norway’s Government Pension Fund Global, Singapore’s GIC and Temasek, Kazakhstan’s National Fund with Samruk-Kazyna, and the State Oil Fund of Azerbaijan — pursue mandates that are not merely different in degree but incompatible in logic. The paper compares them along five dimensions: mandate, source of inflows, withdrawal rule, permitted domestic exposure, and governance and disclosure. It finds that the binding constraint on fund performance is rarely investment strategy; it is the rule governing withdrawals and the institutional separation between asset management and the state’s development agenda. For Uzbekistan, whose Fund for Reconstruction and Development belongs to the development rather than the savings family, the analysis identifies which elements of each model are transferable, and proposes a sequencing in which a codified withdrawal rule and separated governance precede any expansion of the fund’s mandate.