According to Bloomberg New Energy Finance, tax fraud is the carbon trading market’s most egregious form of cheating, affecting about seven percent of this $125 billion market in 2009. In August 2009, seven people were arrested near London for not paying tax on the sale of carbon permits, for a total of £38 million (about U.S. $63 million). The taxes were levied as part of the European Union Greenhouse Gas Emission Trading System, created in January 2005 and based on Directive 2003/87/EC, which was enforced beginning Oct. 25, 2003.