|Push-Push-Pull – new proposition to improve the registries safety|
|Friday, 18 May 2012 22:19|
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How many authorisations are necessary to make emissions allowances transfer request fraud-resistant and, concurrently, non-bureaucratic?
The recent Registry Regulation amendments (Article 21 of the Commission Regulation No 1193/2011 of 18 November 2011) adopted the principle that generally, the approval of an additional authorised representative is required, in addition to the approval of an authorised representative, in order to initiate a transaction, except for transfers to an account on the trusted account list in the Union Registry of the account holder (insignificant exceptions omitted). This was introduced as a reaction to the wave of registry safety violations which ended in allowances being stolen from accounts which in consequence led to multiple judicial disputes (see for instance: Transfer of EUAs as proof of ownership).
This indicates, currently under EU ETS rules the authorisation of two persons makes the transfer viable. The new draft amendments to the California cap-and-trade regulation (see: Major overhaul of the California cap-and-trade - linkage with the Quebec scheme and the KYC-checks substitution for the beneficial holding disclosure provisions) go beyond that.
Draft Changes to Transfer Process (§ 95921 - see: box) propose to replace current “Two key” process by so-called “Push-Push-Pull” method where:
- two authorized or alternate authorized account representatives for the source account file transfer request,
- one authorized or alternate authorized account representative for destination account confirms transfer,
- there are time-limits 48 hours for the filing of the request, 24 hours to confirm.
The collaboration of three persons is in effect necessary to make the transfer.