The empirical study examines the identification of the risks of money laundering in the European Emissions Trading System (EU ETS). The transaction patterns identified and suspicious cases perceived give sufficient grounds for suspected money laundering of at least 300 cases within a trading year.

Six recommendations are made: (1) software-based analyses of the Union registry, (2) report suspicious cases, (3) reform the Union registry, (4) implementation of compliance management systems on the part of account holders, (5) web-based training measures by German Emissions Trading Authority DEHSt, and (6) international risk analyses.