It consequently follows from the said Model Rules that under RGGI rules:


1) the participants of the said emission trading scheme have 10 business days period of uncertainty after concluding agreement relating for instance to the sale of RGGI allowances (under the EUETS rules the transfer is immediate),


2) the recordation is subject to the specific requirements and the Regulatory Agency of the RGGI (or its agent) assess whether they are met as regards a specific transaction within the above-cited periods (under European Union Emission Trading Scheme participants generally immediately know whether transfer they made is effected or not).


The immediate effectiveness of transfers in the European Union Emission Trading Schemes is really valuable feature which probably contributed significantly to the creation of European liquid spot markets in emission allowances. It nevertheless facilitates committing crimes of the sort occurred recently under the EUETS rules, such as VAT fraud or the theft of allowances from the registries. This feature also makes recovering of stolen allowances difficult for the right owners in the face of the speed of potential multiple transfers subsequent to the theft.

But it seems that introducing delays in effecting transfers of allowances (like the above-mentioned provisions of the RGGI model) would mean creating a market of a different sort – maybe safer but nevertheless lacking certain features to which EUETS participants are already accustomed and take them for granted.