Shadow Report on the Activities of ARMA

An analysis of ARMA’s activities in 2024–2025 indicates that the Agency is undergoing a period of large-scale institutional transformation. The period under review was characterised by the simultaneous reform of the legislative framework, changes to the procedures for managing seized assets, and the Agency’s continued performance of its core functions in the areas of identification, tracing, management, realisation and return of assets.

A key achievement of the period was the establishment of a new regulatory framework for ARMA’s activities, aimed at improving the efficiency of seized asset management. At the same time, most of the legislative changes only came into force in late 2025 – early 2026, which makes it impossible to fully assess their practical effectiveness.

Despite some positive changes, the analysis revealed that a number of systemic problems persist. The most significant of these remains the lack of an end-to-end approach to tracking and assessing the asset lifecycle. The existing reporting system allows for the evaluation of the Agency’s individual functions, but does not provide the means to trace an asset’s path from the moment of its identification to its actual return to the state or the realisation of economic benefits from its management or disposal.

Consequently, ARMA’s overall progress in 2024–2025 can be assessed as moderate: the Agency has demonstrated development in its regulatory and organisational capacity, but most reforms have not yet been accompanied by a sufficient number of verifiable results to assess their effectiveness in practice.

• 1. A new operational model for ARMA was established in 2024–2025

Legislative changes have laid the groundwork for a review of approaches to the management of seized assets, introduced new procedures for selecting asset managers, and distinguished between approaches to managing simple and complex assets.

• 2. The asset tracing function demonstrates a high level of activity, but its effectiveness remains difficult to assess

The available reporting does not allow for tracking the subsequent fate of a significant proportion of the identified assets or for assessing their link to subsequent decisions on seizure, management or realisation.

• 3. Legislative reform has not yet been validated by practical results

Despite far-reaching legislative changes and the launch of a new asset management model, most of the new procedures only came into effect towards the end of the period under review; therefore, their actual effectiveness cannot yet be fully assessed.

• 4. The transfer of assets into management continues to be accompanied by significant procedural difficulties

Practice demonstrates the existence of problems with access to assets, lengthy transfer times, interaction with pre-trial investigation authorities, and the preservation of the economic value of assets until management begins.

• 5. The sale of assets generates revenue for the budget, but is characterised by a low proportion of successful auctions

In 2025, the majority of auctions did not result in the sale of assets, and a significant proportion of the procedures were repeat attempts to sell the same lots.

• 6. The Unified State Register of Seized Assets remains an incomplete element of the asset recovery system

​​​​​​​Despite the development of digital infrastructure, the Register does not provide comprehensive tracking of the asset lifecycle and is used only to a limited extent as an analytical tool.

• 7. The further development of Ukraine’s asset recovery system will depend on the implementation of European standards

This applies in particular to the implementation of the provisions of Directive (EU) 2024/1260 on the freezing of assets, various forms of confiscation and an integrated approach to asset recovery.

• Introduce an end-to-end accounting and reporting system covering the full life cycle of assets: from identification and seizure to management, realisation, confiscation and return to the state.
• Conduct a comprehensive assessment of the results of implementing the new asset management model following the completion of its first year of practical application.
• Ensure further harmonisation of Ukrainian legislation with the provisions of Directive (EU) 2024/1260.
• Enhance transparency and accountability in asset management procedures, particularly by introducing public performance indicators for asset managers.
• Ensure the full integration of the Unified State Register of Seized Assets with other state information systems.
• Strengthen the Agency’s human resources and management capacity, including by finalising the establishment of a stable management system.
• Improve inter-Agency coordination between ARMA, law enforcement agencies, the Public Prosecutor’s Office, the courts and the Ministry of Justice.
• Ensure that independent assessments of ARMA’s performance and the implementation of key reforms are carried out on a regular basis.

In 2024–2025, ARMA made the most significant progress in terms of legislative changes, institutional development, and the establishment of new procedures. At the same time, most of the problems identified are systemic in nature and relate to the practical implementation of reforms, the insufficient integration of individual functions, and the lack of mechanisms for a comprehensive assessment of the Agency’s performance.

The main challenge for the next stage of development should be the transition from reforming the regulatory framework to ensuring stable, measurable and publicly verified results in the areas of asset management, realisation and recovery.