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.

The National Agency of Ukraine for Finding, Tracing and Management of Assets Derived from Corruption and Other Crimes (Asset Recovery and Management Agency, ARMA or Agency) is a central executive body with special status, which plays a key role in the system for combating corruption and prosecuting economic crimes. Unlike other bodies, ARMA combines functions covering the full cycle of asset management – from identification to management and/or realisation.

ARMA’s legal status and activities are determined not only by the relevant Law of Ukraine ‘On The National Agency of Ukraine for Finding, Tracing and Management of Assets Derived from Corruption and Other Crimes’ (hereinafter referred to as the Law of Ukraine ‘On ARMA’), but also by a body of regulatory and legal acts governing criminal proceedings, the management of state property, sanctions policy and international legal assistance. This cross-sectoral nature of its mandate necessitates ARMA’s integration into the activities of law enforcement agencies, the judiciary and executive authorities.

ARMA performs the following key functions:

• identifying and tracing assets that may be subject to seizure in criminal proceedings;
• managing seized assets, including transferring them to management with a view to preserving or increasing their economic value;
• realising assets in cases provided for by law;
• maintaining the Unified State Register of Seized Assets;
• facilitating asset recovery, in particular through international cooperation.

In the current climate, ARMA’s role is becoming significantly more important due to the growing volume of seized and sanctioned assets, as well as the need to utilise them effectively in the interests of the state. The Agency’s activities are a key element in Ukraine’s fulfilment of its international obligations regarding asset recovery and integration into the European legal framework.

Furthermore, reform of the system for managing seized assets, including improving ARMA’s effectiveness, has been identified as one of the priorities within international support programmes for Ukraine, in particular the Ukraine Facility, which further underscores the Agency’s particular importance.

The purpose of this Report is to conduct an independent and comprehensive assessment of ARMA’s activities in 2024–2025 in terms of their compliance with its statutory mandate, the stated objectives of state policy and international standards in the field of seized asset management.

The Report aims to:

• identify discrepancies between ARMA’s statutory functions and the practice of their implementation;
• assess the effectiveness of key processes relating to the management, realisation and accounting of assets;
• analyse systemic factors affecting the Agency’s performance;
• identifying the risks associated with maintaining existing practices;
• formulate well-founded recommendations aimed at improving regulatory frameworks, institutional capacity and management procedures.

Particular attention is paid to assessing the extent to which ARMA’s activities ensure the achievement of its key objective – the effective management of seized assets whilst preserving or increasing their economic value and adhering to the principles of transparency and accountability.

This Report covers the period 2024–2025 and focuses on assessing ARMA’s activities in relation to the key functions defined by law, namely:

• identifying and tracing assets;
• management of seized assets;
• the realisation of assets;
• maintaining the Unified State Register of Seized Assets;
• facilitating asset recovery.

At the same time, where necessary to assess the results of reforms introduced during the period under review, the report also takes into account specific regulatory and practical changes that occurred in the first half of 2026. Such references are used solely to assess the state of implementation of new mechanisms and do not alter the main time frame of the study.

The analysis takes into account ARMA’s interaction with other entities, in particular the courts, pre-trial investigation bodies, the public prosecutor’s office, and the executive authorities involved in asset management and realisation processes.

The study examines both the procedures laid down by law and the actual practice of their application, including an analysis of specific cases of asset management and realisation.

The Report focuses on identifying systemic trends, institutional problems and gaps in law enforcement, and is not intended to conduct a full audit of ARMA’s activities or to assess all of the Agency’s individual decisions.

The analysis does not include a detailed examination of:

• all individual asset management cases;
• ARMA’s internal management processes, which are not reflected in publicly available sources;
• issues that fall outside ARMA’s mandate.

At the same time, the report includes an analysis of selected cases and practices that are representative for assessing the overall functioning of the seized assets management system.

ARMA’s activities in 2024–2025 are taking place against a backdrop of full-scale war, a tightening of sanctions policy, and the state’s growing role in managing assets linked to the Russian Federation’s aggression.

The increase in the volume of seized and sanctioned assets, as well as expectations regarding their subsequent confiscation and use for the recovery of Ukraine’s economy, significantly heightens the importance of the effective management of such assets. In this context, ARMA plays a key role as the institution responsible for preserving the economic value of the assets and ensuring the transparency of the relevant processes.

At the same time, ARMA’s activities are the focus of heightened scrutiny from state bodies, international partners, and civil society. This stems both from the need to ensure the effective use of assets and from the risks of a loss in their value, a lack of transparency in procedures and ineffective management. Nor should we overlook the political and public pressure associated with certain assets and their owners.

Ukraine’s integration into the European legal framework and the fulfilment of its international obligations regarding asset recovery lend further significance to this issue. In this context, improving the effectiveness of ARMA’s operations is identified as one of the reform priorities, particularly within the framework of international support programmes for Ukraine.

Thus, the assessment of ARMA’s activities during the period in question has not only institutional but also broader economic and political significance, as it directly affects the effectiveness of public resource management and the level of trust in the anti-corruption infrastructure.

Apart from the Agency itself, the Report is aimed at state authorities responsible for anti-corruption policy, law enforcement agencies, the judiciary, executive bodies, as well as international partners and donors.

Key stakeholders include, in particular, the courts, the public prosecution service, the National Anti-Corruption Bureau of Ukraine (NABU), the State Bureau of Investigation (DBR), the Ministry of Justice of Ukraine, the State Property Fund of Ukraine, the Antimonopoly Committee of Ukraine, as well as the business sector and international organisations.

The assessment of ARMA’s activities in this report is based on a comparative analysis of three key elements:

• the Agency’s statutory mandate;
• ARMA’s official position, in particular its public reporting data;
• the actual practice in carrying out the relevant functions.

This approach makes it possible to identify discrepancies between formally established requirements and the actual practice of their application, as well as to assess the effectiveness of ARMA’s operations in each of the key areas.

The report is structured according to functional principles, in line with ARMA’s main areas of activity. Each analytical section contains:

• a definition of the regulatory standard or expectation;
• a summary of the official position;
• an analysis of actual practice (including statistical data, case studies and case law);
• identified problems and discrepancies;
• an assessment of the risks associated with maintaining existing practices;
• recommendations for addressing them.

In addition, the report employs a triangulation approach, which enhances the reliability of the conclusions and helps to identify discrepancies between official data and actual practice.

This methodological approach ensures a systematic assessment of ARMA’s activities and enables the formulation of well-founded conclusions and recommendations for improving the Agency’s regulatory framework and institutional capacity.

The analysis presented in this Report is based on open and publicly available sources of information covering the regulatory, institutional and practical aspects of ARMA’s activities, in particular:

• Ukrainian legislation governing the activities of ARMA and related institutions;
• official reports, publications and communications from ARMA;
• data from state registers;
• court rulings;
• responses to requests for public information;
• media reports and other open sources.

Particular attention is paid to the analysis of case law and specific asset management cases, which enables an assessment of the actual mechanisms by which ARMA exercises its powers.

The report is not based on access to ARMA’s internal documents and reflects an assessment formed exclusively on the basis of publicly available data. Accordingly, certain aspects of the Agency’s activities may be covered only to a limited extent due to the lack of publicly available information.

In accordance with the Law of Ukraine ‘On ARMA’, ARMA operates as a central executive body with special status, accountable to the Cabinet of Ministers of Ukraine and authorised to trace, manage and realise assets. 

This model involves combining analytical, law enforcement and operational functions within a single institution, which, from the perspective of international practice, is atypical and places heightened demands on internal organisational capacity, the separation of powers and independence from political influence.

International approaches to organising asset recovery systems require clear mechanisms for the separation of powers, internal controls and sufficient human and financial capacity within the bodies responsible for the tracing, management and recovery of assets

In its public reports and communications for 2024, ARMA positions itself as an effective instrument for managing seized assets, emphasising the growth in the volume of assets transferred to its management – measured in tens of billions of hryvnias – as well as in the hundreds of tenders organised to select asset managers. 

Organisationally, the Agency comprises a central office and regional offices. Funding is provided from the State Budget, which covers the costs of staff salaries, administrative support and the institution’s operations.

ARMA’s actual activities in 2024–2025 reveal a number of systemic constraints on institutional capacity.

The Agency’s organisational structure remains centralised: key decisions on asset management are taken at the level of the central administration, whilst regional offices play a limited role. At the same time, the internal structure does not provide for a clear functional separation between asset tracing and asset management, which runs counter to international approaches to the specialisation of such bodies.

ARMA’s staffing capacity is limited. In 2024 and 2025, the maximum authorised strength of the central office was 300 staff, and that of the regional offices was 90 . However, the actual staffing levels were and remain significantly lower, specifically: in 2024 – 194 (central office) and 51 (regional offices), and in 2025 – 229 (central office) and 73 (regional offices) . 

The issue of ARMA’s staffing capacity is not limited to staff numbers alone. A significant proportion of the Agency’s functions requires interdisciplinary expertise, combining knowledge of criminal procedure, anti-corruption legislation, sanctions policy, company law, insolvency, asset valuation, financial analysis, international cooperation and asset recovery mechanisms. In effect, this requires specialists who are equally well-versed in several specialised areas of law and economics. 

A separate issue is staff turnover and the difficulty in recruiting specialists, which objectively affect the performance of ARMA’s functions, particularly regarding the management of complex assets. This creates an imbalance given the volume of assets transferred to its management.

The Agency’s funding also does not match the scale of its functions. According to the Law of Ukraine ‘On the State Budget of Ukraine for 2024’, expenditure on ARMA amounted to 189,064.3 thousand UAH, of which 121,382.7 thousand UAH was allocated to staff remuneration. In fact, UAH 148,032 thousand was spent on wages in 2024. In 2025, a special law allocated 539,111.5 thousand UAH to ARMA, of which 201,812.8 thousand UAH was for labour costs (actual expenditure: 229,344.9 thousand UAH). 

At the same time, the value of assets under ARMA’s management runs into tens of billions of hryvnias, creating a significant gap between resources and responsibilities.

At the same time, certain functions of ARMA defined by law place an additional burden on the Agency’s budget. In particular, the costs of conducting asset valuations for the subsequent selection of a manager are borne by ARMA. In cases where competitive procedures fail to result in the appointment of a manager or have to be repeated, the associated costs are effectively not reimbursed and are met from budgetary funds. This creates an additional financial risk for the institution in a context of limited funding.

The central administration comprises functional units responsible for asset tracing, asset management, legal support, international cooperation and organisational and administrative functions. 

At the same time, regional offices have limited operational autonomy and play a supporting role, which effectively results in a high degree of centralisation in decision-making. 

A separate factor is the instability of the leadership. 

From June 2023 to 30 July 2025, ARMA was headed by Olena Duma, during whose tenure ARMA significantly transformed its political and public image. However, under her leadership, ARMA was repeatedly the subject of media attention, not least due to the head’s own outspoken stance. During the drafting and adoption of amendments to the Law ‘On ARMA’ (Draft Law No. 12374-d), there were frequent instances of public statements by Members of Parliament regarding ARMA’s activities whilst Olena Duma was in office, and her responses to such statements.

Since 30 July 2025, ARMA has not had an appointed Chair; specifically, on 14 August 2025, the Government appointed Yaroslava Maksymenko as Acting Chair.

Noteworhty, on 18 June 2025, Law No. 4503-IX was adopted, amending the competitive selection procedure for the post of ARMA Chair.

The new selection procedure for the post of Chair of the ARMA involves a fundamental change to the selection model by strengthening the role of international partners. The selection committee now consists of six members, three of whom are appointed by the government on the recommendation of international partners, and no decision can be taken without their support. This significantly reduces the risks of political influence that were characteristic of the previous model, where the committee was composed predominantly of representatives from state bodies.

At the same time, the requirements for candidates have been expanded and the selection criteria have been set out in greater detail. Not only lawyers but also economists are now eligible to participate; proficiency in one of the official languages of the Council of Europe has become a mandatory requirement. For the first time, the law clearly defines the criteria for integrity and professional competence, whilst the requirement for political neutrality has been strengthened – candidates must have had no links with political parties for a period of two years. The procedure has also become more structured: it now includes practical tasks, the possibility of additional tests and a mandatory assessment methodology.

Furthermore, the logic and timing of the competition have been amended. The Commission may submit up to two candidates for consideration by the Cabinet of Ministers, which makes the final decision. The procedure must begin two months before the end of the incumbent chairperson’s term of office (previously 45 days), and in the event of early dismissal, the Commission is formed within 14 days. Taken together, these changes make the competition more formalised, predictable and less vulnerable to political influence.

It is precisely this procedure that must be implemented following the Government’s announcement of the competition for the post of ARMA Chair and the appointment, on 25 September 2025, of the members of the Selection Committee responsible for shortlisting candidates for the post.

However, as of the date of this report, the competition for the post of ARMA Chair has not been completed. According to the Selection Committee, following the testing and assessment stages, only one candidate has actually reached the final stage of the selection process. The practical implementation of the new selection model has also revealed a number of procedural issues relating to the completion of the selection process given the limited number of candidates, which has led to delays in the appointment of the Agency’s permanent head.

On 10 June 2026, the selection committee decided to hold a new competition for the post of ARMA Chair, effectively acknowledging the impossibility of completing the current selection procedure and appointing a head based on its results. Consequently, the process of appointing the Agency’s permanent leadership continues, and ARMA has been operating under the leadership of an acting Chair for over ten months.

As at the date of preparation of this report, the results of the independent audit of ARMA’s activities – which is required under Law No. 4503-IX and is one of the key elements of the Agency’s reform – are also unavailable. The absence of audit results limits the possibility of an objective external assessment of ARMA’s performance and the identification of priority areas for further institutional changes.

In accordance with Law No. 4503-IX, amendments were drafter and adopted to the Regulation on ARMA, the Regulation on the Public Oversight Council of the ARMA; and Procedure for the Formation of the Public Oversight Council of the ARMA (Resolution of the Cabinet of Ministers of Ukraine No. 1539 of 28 November 2025).

Despite formal compliance with the law, ARMA’s operational practice reveals a number of systemic gaps between the regulatory model and the actual performance of its functions.

The combination of a wide range of functions within a single body places heightened demands on ARMA’s human, financial and organisational capacity. Given limited resources, this complicates the simultaneous fulfilment of tasks in the areas of asset tracing, management, disposal and international cooperation.

A centralised structure with a limited role for regional bodies reduces the efficiency of asset management. Decision-making is concentrated within the central administration, which causes delays. This is confirmed by cases where the process of transferring assets into management takes a long time, which will be analysed in the following sections. 

The Agency’s staffing capacity (390 vacant posts) is inadequate for the scope of its functions and the volume of assets. The shortage of specialists affects not only operational activities but also the Agency’s ability to develop and implement strategic documents, methodologies and new management approaches. 

ARMA’s funding is disproportionate to the scale of the assets under management (tens of billions of hryvnias). This limits the ability to supervise asset managers and preserve the value of assets, which has repeatedly been the subject of public debate.

A separate systemic problem remains the incomplete and piecemeal implementation of the regulatory framework governing ARMA’s activities. In 2025–2026, the Agency’s legislative framework underwent significant changes, requiring the adoption of a large number of subordinate legislation to launch new asset management procedures. At the same time, some of the regulatory changes came into force with a delay, and the practical implementation of the new mechanisms has not yet been completed. As a result, the Agency continues to operate under a dual system of old and new procedures, creating additional legal uncertainty for market participants and potential asset managers.

Leadership instability and delays in recruitment processes undermine institutional stability. In 2023, the recruitment process for the head of ARMA was marred by delays and criticism regarding transparency. Currently, the lack of stable leadership and the protracted recruitment process are also hindering the Agency’s operational efficiency and the formation of a professional team within ARMA. 

An additional factor contributing to managerial instability is the prolonged absence of appointed deputies to the ARMA Chair following the dismissal of the previous management team. In the absence of a fully formed management team, a significant proportion of strategic and operational decisions are concentrated at the level of the interim leadership, which increases the risks of overburdening, slowing down decision-making processes and the loss of institutional memory. One possible reason for the positions remaining vacant lies in the specific features of the legislative framework, under which the appointment of a new ARMA Chair entails the termination of the powers of the current deputies. However, the effectiveness of a public authority should not depend on the duration of the competition for the position of its head. 

It was only on 19 June 2026 – that is, after the commission had announced on 10 June 2026 that the competition for the post of ARMA Chair would have to be re-run – that the Agency announced the appointment of one Deputy Chair of ARMA.

Limited transparency in reporting makes it impossible to assess the effectiveness of asset management. ARMA’s public reports mainly contain aggregated indicators without any details regarding management outcomes. Furthermore, the structure of the indicators and the way they are presented vary from year to year, which complicates the assessment of the Agency’s performance trends and the conduct of independent monitoring of its effectiveness.

A combination of issues relating to delays in the transfer of assets, ambiguous outcomes of competitive procedures, frequent changes to the regulatory framework and instability in the Agency’s leadership creates additional reputational risks for the Agency. This affects not only the level of public trust in ARMA, but also the willingness of potential managers, investors and other market participants to take part in procedures for managing seized assets.

Maintaining the current model creates risks of inefficient asset management and loss of their economic value, increased political influence over the institution, and corruption due to the concentration of powers. Furthermore, this undermines public and international partners’ trust in ARMA and may negatively affect Ukraine’s fulfilment of its European integration commitments.

To improve the institution’s effectiveness, it is advisable to:

• ensure a transparent and timely competitive selection process for appointing the ARMA Chair and limit the practice of acting in an interim capacity for extended periods;
• review the organisational structure, strengthening the role of regional offices;
• align staffing and financial resources with the volume of assets;
• introduce detailed public reporting.

In 2024–2025, there have been some positive developments in ARMA’s procedural activities and communications; however, key institutional problems – in particular, its structure, staffing capacity, transparency and leadership stability – remain unresolved, indicating limited progress in reforming the Agency.

The Law of Ukraine “On ARMA” defines the identification and tracing of assets as one of the Agency’s core functions. In accordance with Articles 16–18, ARMA must, upon request from pre-trial investigation bodies, the public prosecutor’s office and the courts, take measures to identify and trace assets, ensure international cooperation and provide responses as soon as possible, but no later than within three working days, unless another deadline is specified in the request.
 

This model involves not merely the accumulation of large datasets on property, but the rapid and procedurally useful identification of assets, which enables them to be subsequently seized and, where there are grounds, transferred into administration. 

A similar approach is enshrined in Directive (EU) 2024/1260, which emphasises the early, swift and effective tracing and identification of property as a prerequisite for its subsequent freezing, confiscation or administration.

At the same time, Directive (EU) 2024/1260 significantly expands the operational model of asset recovery authorities compared with ARMA’s current mandate. In particular, it provides for the possibility of the prompt freezing of assets to prevent their disposal or concealment even before the completion of confiscation proceedings. As of 2024–2025, this function is not part of ARMA’s operational model; however, its implementation is envisaged as part of the ongoing alignment of the Ukrainian asset recovery system with EU standards and is being taken into account in the development of the Asset Recovery Strategy for 2026–2030.

In its 2024 report, ARMA identifies the function of asset identification and tracing as one of its most effective areas of activity.

In 2024 :

• the total number of assets identified and traced rose from 96,000 to 146,000;
• 5,449 requests from law enforcement agencies were processed;
• the average response time to requests under the ‘three-day’ procedure was 1.97 days;
• the largest number of requests concerned:
• property offences – 1,153;
• crimes against national security – 1,145 .

In connection with these requests, ARMA reports the detection of:

• UAH 8.3 billion, US$79.9 million, €103.7 million;
• 106,470 plots of land;
• 6,372 residential and 5,980 non-residential properties;
• 15,805 vehicles;
• 1,215 railway vehicles;
• corporate rights with a nominal value of 34.04 billion UAH . 

In 2025 (according to the ARMA report and official statistics ):

• 5,562 requests were received from law enforcement agencies;
• in addition:
• 3,599 requests from the Ministry of Justice,
• 61 from the National Agency for Corruption Prevention (NACP),
• 246 from foreign authorities.

The summary statistics for 2025 indicate:

• 47,171 properties;
• 20,444 vehicles;
• 36.5 billion UAH, 222.2 million US dollars, 131.2 million euros;
• corporate rights worth 57.5 billion UAH. 

Although separate statistics exist for different types of requests, the current reporting structure does not allow asset recovery outcomes to be mapped against their subsequent procedural status. Consequently, it is difficult to evaluate the overall success of the tracing function. 

In 2024, ARMA’s statistics are clearly linked to criminal proceedings, which allows for an assessment of the performance of the asset identification and tracing function within its procedural context.

In 2025, the following trends were observed:

• a slight increase in the number of requests from law enforcement agencies (5,449 → 5,562);
• a significant expansion of the range of entities making requests (the Ministry of Justice, the National Agency for Corruption Prevention, foreign authorities);
• the continued breakdown of assets by type (property, vehicles, funds, etc.).

At the same time, the key change lies in the altered logic of data aggregation:

• in 2024 – statistics compiled within the framework of criminal proceedings;
• in 2025 – the results are presented in aggregate form across all areas of ARMA’s activities (criminal proceedings, sanctions tracking, inter-Agency cooperation, etc.).

This means that, despite the availability of comparative tables:

• the figures for 2024 and 2025 are only partially comparable;
• it is impossible to determine what proportion of assets in 2025 was identified specifically through criminal proceedings;
• consequently, it is impossible to assess the dynamics of the tracing function’s effectiveness in its ‘pure’ form (that is, ARMA’s public reporting allows for an assessment of the volume of work carried out (number of requests, individuals, information enquiries and processing times), but contains significantly less information on the subsequent impact of tracing results on the seizure, management or confiscation of assets).

Transparency International Ukraine has also reached a similar conclusion regarding the gap between identified assets and their subsequent fate. In particular, TI Ukraine, analysing ARMA’s report for 2024, noted that out of 12,352 identified properties, only 1,512 were seized, whilst 289 were transferred to ARMA’s management; of the 106,470 identified plots of land, 1,759 were seized and 305 were transferred to ARMA; despite the significant volumes of identified funds, the rates of seizure and subsequent transfer also remained low. According to TI Ukraine’s estimates, on average around 7.8% of identified assets were seized, whilst less than 3% of the total volume of traced property was placed under administration. This does not mean that ARMA is not functioning, but it does mean that the ‘identified’ figure cannot be regarded as a sufficient indicator of effectiveness without analysing the subsequent procedural fate of the asset. 

Unlike the 2024 report, the data published by ARMA for 2025 does not allow for determining the total number of assets identified specifically through the asset tracing function in criminal proceedings, nor for tracking their subsequent procedural fate. Consequently, the available public reports do not allow one to trace the relationship between the individual stages of the asset life cycle or to determine what proportion of the traced assets were subsequently seized, transferred to administration, realised or confiscated. 

The international component deserves separate attention. The Law of Ukraine “On ARMA” explicitly includes international cooperation among ARMA’s tasks in the field of asset identification and tracing. The 2024 report contains an example of such a search: with the support of foreign competent authorities, as part of Ukrainian criminal proceedings concerning human trafficking and money laundering, 16 bank accounts with balances exceeding 6 million US dollars, 3 properties, 2 vehicles and shares in foreign companies worth over 400 thousand euros were identified. This case demonstrates the potential of international cooperation as a tool for tracing assets abroad.

At the same time, ARMA’s 2025 report does not contain a similar level of detail regarding the results of international cooperation. Although the report contains information on assets identified and traced abroad, it does not allow one to track their subsequent procedural fate, the level of actual recovery, or the economic outcome of international cooperation. This makes it difficult to assess the effectiveness of international activities and their contribution to the overall process of asset recovery.

The main problem with this area of work is that ARMA publicly reports primarily on the volume of assets identified, but much less on their subsequent procedural effectiveness. As a result, the ‘identified’ figure functions as a standalone indicator of success; although ARMA has begun to publish selected figures on the subsequent seizure of traced assets, the available reporting still does not allow for tracking their subsequent movement through the subsequent stages of the asset recovery cycle. This is precisely why large volumes of identified assets do not always translate into tangible anti-corruption or criminal procedural outcomes. 

A second systemic problem is the limited comparability of official statistics across years. Although the ARMA report for 2025 contains specific indicators on criminal proceedings, unjustified assets, sanctions mechanisms and international cooperation, changes in the structure and approaches to presenting information compared with 2024 make it difficult to directly compare individual indicators and assess their trends. This is a significant issue in its own right, as the problem lies not only in performance but also in the reporting format, which affects the ability to carry out external oversight and independent analysis of the Agency’s activities.

The third issue is the limited ability to assess the practical outcome of the asset tracing function. Formally, ARMA adheres to the established deadlines: in 2024, responses to ‘three-day’ requests were provided within an average of 1.97 days. At the same time, the indicator of the speed of processing requests does not, in itself, allow for an assessment of the practical value of the results obtained for criminal proceedings. Due to the absence of information in public reports regarding the subsequent use of the search results by pre-trial investigation bodies, the prosecution service and the courts, it remains difficult to assess the contribution of the asset tracing function to achieving the final procedural outcome. Under such circumstances, assessing the effectiveness of this area of activity effectively boils down to analysing the volume of work carried out and the time taken to complete it, rather than evaluating its effectiveness.

The fourth problem is the absence of end-to-end performance indicators in public reporting. ARMA publishes individual indicators regarding the freezing of assets, but does not provide end-to-end tracking of their subsequent movement between the stages of freezing, management, realisation, confiscation and return. As a result, the assessment of the effectiveness of the asset tracing function is effectively replaced by an assessment of the volume of work carried out, which does not allow for an objective determination of the Agency’s contribution to achieving the final outcome. 

If the current approach persists, ARMA will continue to be able to report high figures for ‘identified’ assets without a commensurate real impact on their seizure, preservation and subsequent management. This creates a risk of a misperception regarding the effectiveness of the function among both national authorities and international partners. Furthermore, when data on asset tracing is not linked to data on their seizure and transfer, there is an increased risk that some assets will effectively be lost to the proceedings even before they are seized. This state of affairs runs counter to the very logic of asset recovery, where tracing should not be an end in itself, but rather the first stage in effectively depriving the offender of economic resources. 

Furthermore, the lack of preparation for the implementation of the new instruments provided for in Directive (EU) 2024/1260, in particular the mechanisms for the prompt freezing of assets, may complicate the further adaptation of the Ukrainian asset recovery system to the requirements of European Union law and create additional challenges in the process of European integration.

In this regard, it is advisable to recommend that ARMA move from reporting on ‘gross’ detection figures to end-to-end statistics covering the entire chain: 

identified → seized → transferred to management / realised / confiscated. 

Separately, it is necessary to restore and standardise the year-on-year comparability of public data, with a clear breakdown of statistics into at least the following categories: 

• criminal proceedings;
• sanctions cases;
• unjustified assets; 
• assets of banned parties; 
• international requests. 

It is also worth supplementing the performance assessment not only with the response time indicator, but also with indicators of subsequent procedural utility: the proportion of assets seized following ARMA’s response, and the proportion of assets transferred to management. 

Moderate progress can be observed in 2024–2025. 

On the one hand, ARMA has maintained high volumes of requests from law enforcement agencies and, at least formally, has continued to process them swiftly; in 2025, the number of such requests even increased slightly compared with 2024. 

On the other hand, the quality of public reporting has not improved; indeed, in terms of year-on-year comparability, it has actually deteriorated, whilst the data on the low proportion of assets progressing from the ‘identification’ stage to the ‘seizure’ and ‘management’ stages do not provide grounds for suggesting a systematic improvement in the effectiveness of this particular function. 

Analysis shows that ARMA’s reporting system in the area of asset identification and tracing remains focused primarily on recording actions taken and the volume of information processed. At the same time, indicators that would allow an assessment of the subsequent fate of identified assets and their impact on the outcomes of criminal proceedings or the asset recovery process remain limited. This creates a situation where a high level of operational activity does not always correlate with the achievement of the final result.

The management of seized assets is a core function of ARMA, which is intended to ensure the preservation of the economic value of the asset until the case is resolved on its merits, as well as, where possible, to generate revenue for the state. It is precisely this objective that is enshrined in the Law of Ukraine ‘On ARMA’ following the amendments introduced by Law No. 4503-IX.

In accordance with the legislation, management may be carried out by:

• transferring the asset to a manager selected on a competitive basis;
• the disposal of the asset in cases expressly provided for by law.

In this section, we focus specifically on the transfer of an asset to a manager, which is a key element of asset recovery, designed to transform the seizure of an asset from a formal restriction into a tangible economic outcome.

Prior to the legislative changes of 2025, the management of seized assets by ARMA was regulated by ARMA’s methodological guidelines, which were approved by internal order , as well as by the general provisions of the Law of Ukraine ‘On ARMA’. However, this was insufficient to establish an effective procedure for selecting managers. In practice, this led to a management model that depended largely on the Agency’s own administrative practices, rather than on a clearly defined legal procedure.

The actual asset management process worked as follows: after an asset was transferred to ARMA’s management, the Agency carried out a basic assessment of the feasibility of transferring it to a third party, after which the process of selecting a manager was initiated. Such selection generally took place in accordance with a procedure that was intended to comply with the requirements of public procurement legislation, utilising elements of market analysis (preliminary market consultations).

At the same time, the absence in the legislation of mandatory stages for the preliminary assessment of an asset, management planning and a clear classification of assets by complexity meant that decisions on the method of management were taken on a case-by-case basis and without any consistency. As a result, the timeframes for transferring assets to management could vary significantly, and the procedure itself depended on the type of asset being transferred, its level of complexity and the availability of interested managers in the market.

Monitoring of management effectiveness was carried out, but it was not systematic in nature and was constrained by both regulatory and institutional factors. This made it difficult to assess whether the key objective – preserving or increasing the economic value of the assets – was being achieved.

Overall, the previous model functioned as a system in which asset management commenced once procedural issues had been resolved, rather than as a proactive process aimed at the rapid and effective integration of the asset into economic circulation.

Consequently, the previous model was characterised by a lack of sufficient procedural detail, limited mechanisms for the preliminary valuation of assets and oversight of management outcomes, which created risks of procedural delays and a loss of the assets’ economic value.

Law No. 4503-IX introduced a fundamentally different approach to the management of seized assets, replacing the fragmented and reactive model with a more structured system focused on achieving economic results. However, it is worth noting that Articles 21-3, 21-4and 21(-5) of the Law of Ukraine “On ARMA”, which set out the procedures for selecting managers and procuring the relevant services, did not come into force until 30 January 2026.

Whereas previously the management process effectively began with the search for a manager, the new model provides for a step-by-step approach that begins with an analysis of the asset itself. Following the transfer of the asset to ARMA, it is identified and assessed for the feasibility of effective management; on this basis, a preliminary management plan is drawn up, setting out the optimal use of the asset, expected outcomes and key risks.

An important innovation is the classification of assets into simple and complex categories, which enables the application of different manager selection procedures based on their economic and operational characteristics. The selection of a manager becomes more structured, involving preliminary qualification and clearer assessment criteria; where it is not possible to appoint a manager through the main procedure, a fallback mechanism for procuring management services may be used.

The new model places particular emphasis on monitoring the effectiveness of management. The legislation provides for systematic monitoring of the manager’s activities and an assessment of management outcomes, as well as the possibility of changing the chosen model should it prove ineffective.

Thus, asset management is transforming from an administrative procedure into a full-fledged management cycle, encompassing analysis, planning, implementation and control, and aimed at preserving or increasing the economic value of the assets.

To launch this model, the Cabinet of Ministers and other state bodies adopted a number of necessary subordinate legislation between late 2025 and the first half of 2026. In particular, the following acts were approved:

• The procedure and timeframes for the development, approval and amendment of the indicative asset management plan – CMU Resolution No. 1540 of 28 November 2025; 
• The procedure for selecting a manager of a simple asset – CMU Resolution No. 166 of 5 February 2026; 
• The procedure for selecting a manager of a complex asset – Resolution of the Cabinet of Ministers of Ukraine No. 167 of 5 February 2026; 
• The procedure for conducting an auction to appoint a manager of a complex asset (assets) – Resolution of the Cabinet of Ministers of Ukraine No. 167 of 5 February 2026;
• The procedure for conducting an auction to appoint a manager of a simple asset (assets) – Resolution of the Cabinet of Ministers of Ukraine No. 166 of 5 February 2026;
• The procedure for the pre-qualification of participants for the appointment of a manager for a simple asset (assets) using an electronic procurement system – Resolution of the Cabinet of Ministers of Ukraine No. 166 of 5 February 2026;
• Matters relating to the Commission for the Appointment of a Manager of Complex Assets – Resolution of the Cabinet of Ministers of Ukraine No. 138 of 5 February 2026;
• Procedure for monitoring the effectiveness of asset management – Resolution of the Cabinet of Ministers of Ukraine No. 136 of 5 February 2026; 
• Procedure for the calculation by the ARMA of the expected value of the subject of procurement of asset (assets) management services – Resolution of the Cabinet of Ministers of Ukraine No. 137 of 5 February 2026.
• On certain issues relating to the transfer by prosecutors and the assumption of management by ARMA of seized assets – Joint Order of ARMA and the Office of the Prosecutor General No. 46/58 of 23 February 2026;
• Procedure for approving the asset manager’s expenses – Resolution of the Cabinet of Ministers of Ukraine No. 256 of 25 February 2026;
• On establishing the minimum sum insured under an asset manager’s liability insurance policy – Resolution of the Cabinet of Ministers of Ukraine No. 257 of 25 February 2026;
• Procedure for the safekeeping of assets taken into management by the ARMA – Resolution of the Cabinet of Ministers of Ukraine No. 433 of 1 April 2026.
• On amendments to the Procedure for the operation of the electronic procurement system and the authorisation of electronic trading platforms – Resolution of the Cabinet of Ministers of Ukraine No. 484 of 10 April 2026;
• On the approval of model asset management agreements – Resolution of the Cabinet of Ministers of Ukraine No. 537 of 30 April 2026;
• On the approval of the Methodology for determining the feasibility of managing an asset (assets) – Resolution of the Cabinet of Ministers of Ukraine No. 710 of 4 June 2026.

At the same time, even after the reform of the legislation, the asset management system continued to operate under conditions where several legal regimes co-existed for different categories of assets. Alongside the new model for the management of seized assets provided for by the Law of Ukraine ‘On ARMA’, a separate regulatory framework continued to apply to assets forfeited to the state or transferred to special management regimes, in particular the Procedure approved by Resolution of the Cabinet of Ministers of Ukraine No. 1233 of 21 November 2023, to which amendments were also made in 2025.

As a result, in practice during 2024–2025, asset management was carried out under at least two different regulatory models: one for assets seized in criminal proceedings and another for assets that, as a result of the application of a sanction in the form of forfeiture to the state, were transferred to state ownership. Such fragmentation of regulation made it difficult to establish a unified approach to asset management and created risks of ambiguous delineation of powers between state bodies in cases where the legal status of an asset changed.

Modern approaches to the management of seized assets, developed at the level of international organisations – in particular the Stolen Asset Recovery Initiative (StAR), the Financial Action Task Force and within the framework of EU practice – are based on the principle that asset management should not be a mere formality, but a structured and professional process aimed at preserving the economic value of the asset.

The key elements of such a model include: preliminary identification and valuation of the asset prior to making decisions on its use; management planning, including the determination of the optimal model and expected outcomes; classifying assets by complexity, which allows different approaches to be applied to simple and complex assets; engaging professional managers on a competitive basis; and systematic monitoring of management effectiveness with the option to adjust the chosen model.

The legislative changes of 2025 generally reflect the implementation of these approaches in Ukraine. In particular, the Law introduced a mandatory preliminary assessment of assets, along with a draft management plan, the classification of assets into simple and complex categories, structured procedures for the selection of managers, and formalised monitoring of management effectiveness.

Thus, the new asset management model in Ukraine is conceptually in line with international standards; however, its effectiveness depends on the comprehensiveness and quality of the practical implementation of these tools.

In its reports for 2024–2025, ARMA positions asset management as one of the key areas of its activity and the main source of economic benefit from the seizure of property. The main emphasis is placed on the financial results of management, the number of assets transferred, and the volume of revenue to the State Budget.

According to the 2024 report, the Agency reported revenue of approximately 1.5 billion UAH from asset management, with the total value of cash assets under management exceeding 12 billion UAH, and the implementation of over 300 monitoring measures regarding the activities of asset managers. 

In its 2025 report, ARMA declares further growth in key indicators: the conclusion of 38 management contracts via the Prozorro platform and revenue to the budget of over 2.17 billion UAH.

At the same time, quantitative and financial performance indicators predominate in the public reporting. Significantly less attention is paid to assessing the timeframes for transferring assets into management, the actual results of managing specific categories of assets, issues regarding access to assets, and the impact of procedural decisions in criminal proceedings on the effectiveness of management.

Asset management practice in 2024–2025 was characterised by a shift from a model involving a limited number of actual transfers of assets into management to a more active use of this instrument. At the same time, the changes mainly concerned quantitative indicators and regulatory reform of the system, whilst it is still too early to assess the effectiveness of the new management model.

One of the most telling indicators of these changes was the increase in the number of asset management contracts. Whilst only 7 asset management contracts were concluded in 2024, by the end of 2025, 38 management contracts had already been concluded via the Prozorro system. In addition, under a special procedure, a further 14 contracts were in force in 2025 concerning assets transferred to management on the basis of orders from the Cabinet of Ministers of Ukraine. Thus, during 2025, ARMA significantly expanded the practice of transferring assets to managers and made more active use of the asset management mechanism.

A separate category was formed by so-called strategic assets transferred under a special procedure. These primarily include assets in the energy sector transferred to the management of PJSC ‘UKRNAFTA’, in particular the ‘Hlusko’ petrol station network, the corporate rights of PJSC ‘VK ‘Ukrnaftoburinnya’, LLC ‘Sirius-1’, LLC ‘Sakhalinskoe’ and other assets, as well as the corporate rights of PJSC ‘Lviv Insulator Company’, transferred to PJSC ‘NEC ‘Ukrenergo’. It was this category of assets that subsequently accounted for the bulk of the financial returns from management.

Alongside the increase in the number of contracts, there was also an expansion in the actual practice of transferring assets to managers. An analysis of the timeframes for the actual transfer of assets to managers indicates significant inconsistency in practice during 2024–2025. 

In 2024, the average time between the conclusion of a management contract and the signing of the handover certificate was 5 months and 19 days. The shortest transfer period was 151 days (the vessel ‘EMMAKRIS III’), whilst the longest reached 409 days (1 year, 1 month and 13 days) for non-residential premises at 18 Pavlivska Street, Kyiv. 

In 2025, the situation improved: the average handover period fell to 27 days, whilst the longest recorded period was 142 days for railway carriages. At the same time, practice remained inconsistent – some assets were handed over almost immediately after the contracts were concluded; in particular, the ‘Zhovtnevy Palace’ complex was handed over the very next day. 

Furthermore, as at the end of 2025, certain assets had still not actually been transferred to the managers under handover certificates, despite the management contracts having been concluded. Examples of this include a non-residential building at 71-B Velyka Vasylkivska Street, Kyiv, as well as 1,697 and 51 railway carriages respectively. Practice shows that a prolonged failure to physically transfer assets may also lead to the termination of the management contracts themselves. For instance, the management agreement concerning non-residential premises, motor vehicle parking spaces and machinery storage spaces at 34-A Yevhen Konovalets Street, Kyiv, concluded with TRUB-INZHBUILD LLC in October 2024, was terminated in April 2025 without the assets having actually been transferred to the manager. A similar situation arose regarding the corporate rights of ‘VENTA.LTD’ LLC, where, following the conclusion of the management agreement and a lengthy wait for the necessary approvals, actual management never commenced, and the agreement was terminated in February 2026.

As at the end of 2025, 19 managers were managing assets and asset groups. At the same time, the management structure was characterised by a significant concentration of assets amongst a limited number of entities. 

The five largest managers held 24 assets, or around 58.5% of the total number of management agreements. The largest managers were VOEDGER PLUS LLC, UKRNAFTA PJSC, PRIORITET Municipal Enterprise, KOMBINAT PLUS LLC and KAMPARITET Municipal Enterprise. Thus, despite the expansion of the pool of managers, a significant portion of assets remained concentrated amongst a relatively small number of market participants.

In parallel with the increase in the number of contracts, the financial results of asset management have risen significantly. Whilst ARMA reported revenue from asset management of around 1.5 billion UAH for 2024, the total revenue to the State Budget of Ukraine for 2025 amounted to 2.178 billion UAH. At the same time, the estimated amount of guaranteed payments stipulated under the terms of the concluded asset management contracts amounted to just 231,929,527.13 UAH. Thus, actual revenue exceeded the guaranteed payments by almost 1.95 billion UAH. This surplus is primarily attributable to assets in the energy sector that generate revenue exceeding the baseline (guaranteed) obligations set out in the management agreements.

The main source of this financial result in 2025 was the strategic assets of the energy sector. The largest revenues were generated by the corporate rights of PJSC ‘VK ‘Ukrnaftoburinnya’ (UAH 1.82 billion), the ‘Glusko’ petrol station network (UAH 257.8 million) and the corporate rights of Sakhalinske LLC (UAH 56.8 million), managed by PJSC ‘UKRNAFTA’. At the same time, the revenue structure remained extremely uneven: around 98 per cent of all revenue was generated by a limited number of large assets, whilst some assets generated no revenue at all due to delays or the inability to actually commence management. This indicates that ARMA’s financial results are heavily dependent on a few large assets and does not allow for any conclusions to be drawn regarding the effectiveness of the asset management system as a whole.

This indicates that financial results are improving; however, the reason for this is by no means the systemic efficiency of the old management model currently in use, nor the implementation of a new one that has not yet become operational.

The significant increase in the number of manager selection procedures in 2025 warrants separate note. According to ARMA’s data, the number of tenders for the selection of managers increased almost fivefold compared with the previous year. An analysis of data from the Prozorro system confirms this trend: in 2024, 33 tenders for the selection of asset managers were announced (including repeat procedures), whereas in 2025 the figure had risen to 212. This growth indicates a significantly more active use of the mechanism for transferring assets into management and preparations for the transition to the updated asset management model. At the same time, the quantitative increase in competitive procedures does not in itself indicate improved management efficiency, as assessing the results of the new system requires an analysis of the actual transfer of assets, the performance of asset managers and the economic impact of management.

Alongside these quantitative changes, the legislative framework for asset management was reformed in 2025. Law No. 4503-IX introduced new procedures for the transfer of assets into management, as provided for in Articles 21-3, 21-4and 21(-5) ofthe Law of Ukraine “On ARMA”, as well as a differentiated approach to different categories of assets. However, despite these provisions coming into force at the end of January 2026, as of early June 2026 , there is virtually no established practice regarding their application. The tender commission for complex assets only began its work in April–May 2026; therefore, it is currently too early to assess the effectiveness of the new management model.

At the same time, the actual development of new practices for transferring assets into management is proceeding more slowly than envisaged by the reform. As at the date of this Report, there are no completed examples of the transfer of simple assets into management under the new procedures (i.e. individual movable or immovable property). With regard to complex assets, the tender committee has only just begun its work, and the number of tenders announced remains limited. As of 1 June 2026, tenders to appoint managers had been announced for only three complex assets, including the ‘KRYSHTAL’ business centre, the assets of SKN ‘Suchasna Komertsiyna Neruhomist’ LLC, and the corporate rights of the IDS Ukraine group.

In practice, this means that a significant proportion of assets remain outside the new management model, and it is impossible to assess its effectiveness, not only because the legislation is new but also due to the lack of a sufficient number of completed procedures. 

Furthermore, it should be borne in mind that one of the key elements of the reform was the need to carry out a full identification of assets already under ARMA’s management. At the same time, according to the Agency’s 2025 public report, the main focus is currently on asset inventory and initial classification. Following the inventory and identification process, 60,274 assets were recorded in ARMA’s management accounts, of which only 20,753 were classified as assets with high management potential. This indicates that the practical implementation of the new model is largely still at the preparatory stage, rather than at the stage of fully launching management procedures.

Overall, asset management practices in 2024–2025 indicate a significant intensification of ARMA’s activities in this area. Whilst in 2024 the key challenge remained the launch of mechanisms for transferring assets into management and the limited number of contracts concluded, in 2025 the focus shifted to issues of financial performance, the actual transfer of assets to managers, the quality of management and the sustainability of the established system. At the same time, the available indicators currently allow us to assess primarily the scale of the Agency’s activities and the financial performance of individual assets, but do not provide sufficient grounds for conclusions regarding the long-term effectiveness of the new legislative model for asset management.

Despite the increase in the number of management agreements and financial inflows to the budget, the practice of transferring assets to management continues to reveal a number of systemic problems that affect ARMA’s ability to ensure the preservation and growth of the economic value of seized assets.

• The duration of the process of transferring assets to management and losses in their value

One of the key problems remains the significant time lag between the appointment of a manager and the actual commencement of asset management. Even after the completion of the tender procedure and the conclusion of the contract, the asset may not be transferred to the manager for a long time, creating risks of it lying idle, losing economic value or deteriorating in technical condition. A telling example is the case of the non-residential premises at 18 Pavlivska Street in Kyiv, transferred to the management of the municipal enterprise ‘KAMPariet’, where 409 days (1 year, 1 month and 13 days) elapsed between the signing of the contract and the actual signing of the handover certificate.

• Restricted access to assets and the inability to manage them effectively

The actual transfer of an asset into management does not always mean that it can be effectively managed. In a number of cases, ARMA or the appointed manager face problems with access to the property, a lack of necessary documentation, or a lack of actual control over the asset. One of the best-known examples is the house of the former Minister of Internal Affairs, Vitaliy Zakharchenko, in the centre of Kyiv, to which the Agency’s representatives were unable to gain access for a long time due to the lack of keys. Such situations highlight the gap between the legal transfer of an asset and the ability to actually manage it.

The problem of accessing assets is not limited to isolated technical difficulties and, in some cases, takes on a systemic nature. For instance, whilst attempting to transfer the Trade Union House to ARMA’s management, the Agency faced a de facto blockade of access to the property by organised groups who controlled the premises and obstructed the enforcement of court rulings. Furthermore, the situation was complicated by multiple court rulings ordering the seizure of the asset, which created legal uncertainty regarding its future management. Only after the obstacles had been removed and actual access to the premises secured was the asset transferred to the management of the municipal enterprise ‘KAMPariet’.

Similar problems arose in relation to other economically significant assets. A telling example is the case of the ‘Gulliver’ shopping and entertainment centre, where the process of transferring the asset was accompanied by protracted disputes over control of the property, restrictions on actual access to the premises, and difficulties in determining the future management model. Despite two competitive tendering procedures, no manager was selected for the asset, and the subsequent change in the property’s legal status and the transfer of ownership to state-owned banks effectively halted the process of transferring it to ARMA’s management. These examples demonstrate that, even in the presence of court rulings and formally completed procedures, the Agency is not always able to promptly gain actual control over an asset and ensure its effective management.

• Asset valuations becoming outdated due to lengthy transfer periods

A separate systemic problem remains the dependence of the asset transfer procedure on the validity of their valuation. Under the law, a property valuation report remains valid for six months from the date of its preparation. In cases where the transfer of an asset to management is delayed for a prolonged period, there is a need to carry out a revaluation, as the previous valuation becomes outdated for the purposes of management decision-making and the conduct of competitive tendering procedures. This creates an additional procedural burden and increases the duration of the transfer of assets to management.

The issue takes on particular significance given that certain asset transfer procedures in previous years lasted considerably longer than six months. Under such circumstances, delays may necessitate repeated updates to asset valuations, which, in turn, requires additional financial resources and organisational efforts. At the same time, the funding available for such costs remains limited, creating risks of a further accumulation of assets that are formally under ARMA’s administration but are not, in fact, involved in economic circulation.

• The dependence of management on procedural decisions in criminal proceedings

The effectiveness of asset management depends largely on decisions made by pre-trial investigation bodies and courts, which are beyond ARMA’s control. In cases where seizures are lifted or the procedural status of assets is changed, the competitive procedures that have been carried out may lose their practical significance. A telling example is the case of a property in Lviv, for which a management agreement was concluded with TRANSGOSP LLC; however, following the lifting of the seizure order, the asset was never actually transferred to the manager. Consequently, the selection procedure carried out did not result in the commencement of asset management.

At the same time, practice shows that a change in the procedural status of an asset can affect its management even after it has been physically transferred to the manager. A telling example is the case of one of the assets of the Stereo Plaza concert and entertainment complex in Kyiv. The management agreement for the premises at 119-A Valerii Lobanovskyi Avenue was concluded on 31 October 2025, and just 11 days later the asset was transferred to the manager under a handover certificate. However, following the lifting of the seizure on 25 December 2025, the management agreement was terminated. During the period under management, the asset generated revenue for the state budget amounting to over 950 thousand UAH. This case demonstrates that even the successful management of an asset may be terminated as a result of subsequent procedural decisions that lie beyond the control of ARMA and the manager.

It is also worth noting the piecemeal nature of the transfer of interrelated assets. The effectiveness of asset management can be significantly reduced in cases where interrelated assets are transferred to ARMA through separate procedural decisions and at different times. Under such circumstances, the Agency is forced to organise the management of individual parts of the property complex without being able to simultaneously cover all assets that functionally constitute a single entity.

Examples include specific cases involving the transfer of health resort complexes, where the property was transferred to ARMA gradually and on the basis of different procedural decisions. This approach complicates the valuation of assets, the preparation of competitive tendering procedures, the determination of the optimal management model and the search for potential managers. As a result, an economically coherent asset may be treated as a collection of separate properties, which reduces its investment appeal and potential management efficiency.

• Inadequate quality of individual manager selection procedures

Individual cases highlight the risks of a formalistic approach to setting requirements for potential managers. In particular, during the selection of a manager for the vessel ‘EMMAKRIS III’ and nine other arrested vessels, the initial tender documentation contained limited requirements regarding the experience and specialisation of the prospective manager. Subsequently, the Agency was forced to revise the terms and conditions and repeat the selection procedure. This demonstrates that the improper definition of criteria can delay the start of asset management and reduce the effectiveness of tender procedures.

• Lack of a comprehensive assessment of management performance

ARMA’s public reporting focuses primarily on the volume of revenue generated for the budget, the number of contracts concluded and the number of control measures carried out. At the same time, the Agency does not publish systematic indicators that would allow for an assessment of the effectiveness of the management of individual assets, the extent to which their value has been preserved, the proportion of assets that are effectively idle, or the results of monthly monitoring of managers’ activities. Under these circumstances, even significant financial results do not allow conclusions to be drawn about the effectiveness of the management function as a whole, as the outcomes regarding a significant proportion of the transferred assets remain unknown.

• Lack of sufficient practical experience to assess the new management model

Despite the completion of the legislative reform of asset management, as of June 2026, the new procedures have not yet generated sufficient practical experience to assess their effectiveness. This means that it is currently impossible to draw a well-founded conclusion as to whether the new model is capable of addressing the problems characteristic of the previous approach to transferring assets into management. Key conclusions regarding the reform’s effectiveness can only be drawn once sufficient practical experience with the new procedures has been accumulated and the first comparable results become available.

• Lack of a standardised unit of measurement for assets.

An analysis of ARMA’s reporting indicates the absence of a single approach to defining and accounting for assets as a statistical unit. In different cases, a single asset may be considered to consist of individual corporate rights, consignments of goods, property complexes, individual railway carriages, boxes of goods or other items, which complicates the comparison of indicators relating to the transfer, management and disposal of assets. Under these circumstances, quantitative indicators of ARMA’s performance require cautious interpretation, as they do not always reflect objects that are comparable in economic terms.

1. Further loss of the economic value of assets. If the timeframes for transferring assets into management remain lengthy, the state will continue to lose potential revenue from their use, and individual assets may lose their market value even before actual management begins.
2. Persistence of the gap between legal and actual management of assets. Even after the transfer of assets to ARMA or the appointment of a manager, obstacles to the effective control and operation of the property may remain, thereby reducing the efficiency of the entire management system.
3. Low predictability of asset management. The dependence of management on subsequent procedural decisions in criminal proceedings creates risks of disruption to procedures already underway and the loss of the results of tenders that have been held.
4. Repetition of the shortcomings of the previous model within the new reform. As the new procedures have not yet undergone a full cycle of practical implementation, there remains a risk that some of the problems of the previous system will be carried over into the new management model.
5. Fragmentation of approaches to different categories of assets. The further development of separate procedures for seized, sanctioned and confiscated assets without proper coordination may complicate the formation of a unified and consistent asset management system.
6. Limited accountability for management outcomes. If public reporting continues to focus primarily on revenue figures and quantitative indicators, it will remain difficult to assess the actual effectiveness of asset management and the impact of ARMA’s activities on preserving asset value.
7. Declining confidence in the asset management reform. In the absence of tangible practical results from the new model, scepticism regarding the effectiveness of the reforms may grow, both among potential asset managers and among international partners.

(1) Complete the harmonisation of legislation in the field of asset management. It is necessary to resolve existing conflicts and inconsistencies between the Law of Ukraine ‘On ARMA’, the Criminal Code of Ukraine and the Code of Criminal Procedure of Ukraine, as well as other regulatory acts affecting the transfer of assets into management and the exercise of the Agency’s relevant powers.

(2) Ensure systematic monitoring of the practical application of the new asset management model. Given that the procedures set out in Articles 21-3, 21-4and 21-5  of the Law of Ukraine “On ARMA” are, in fact, only just beginning to establish a body of case law, it is advisable to introduce regular analysis of the results of their implementation and public reporting on the first cases of assets being transferred to management under the new procedures.

(3) Strengthen cooperation between ARMA, pre-trial investigation bodies, prosecutors and the courts at the stage of transferring assets into management. This will minimise instances where a change in the procedural status of an asset or a lack of necessary information prevents the commencement of actual management following the completion of the competitive procedure.

(4) Strengthen mechanisms for the preliminary preparation of assets prior to their transfer to management. Before competitive procedures commence, it is necessary to ensure the proper identification of assets, verification of their actual condition, accessibility, the completeness of documentation and the existence of any restrictions that may affect subsequent management.

(5) Strictly adhere to the timeframes between the appointment of a manager and the actual transfer of the asset into management. When establishing new practices, particular attention should be paid to the stage of the actual handover of assets, as it is delays at this stage that pose the greatest risks of a loss in the economic value of the assets.

(6) Refine approaches to the selection of managers for complex assets. Qualification requirements must take into account the specific characteristics of particular asset categories and ensure proper verification of the professional capacity of potential managers to manage the relevant assets effectively.

(7) Ensure the development of uniform approaches to the management of different categories of assets. As legislation is further developed, it is advisable to minimise the fragmentation of procedures relating to seized, sanctioned and confiscated assets, ensuring a management model that is as harmonised and predictable as possible.

(8) Introduce an expanded system of public reporting on asset management. Alongside financial results, it is advisable to regularly publish indicators of the time taken to transfer assets into management, the results of monitoring managers’ activities, information on assets that have not actually been transferred into management or do not generate economic returns, as well as indicators of the preservation or increase in the value of assets.

In 2024–2025, significant progress was made at the regulatory level in the field of asset management. Legislative reform created a new model for the management of seized assets, introduced a differentiated approach to different categories of assets, and laid the foundations for a move away from the previous system, which had long been criticised for its excessive procedural complexity and low efficiency.

At the same time, the practical results of the reform are as yet too limited to be properly assessed. As of early June 2026, the new procedures had not yet been applied sufficiently in practice, and most of the systemic issues identified relate specifically to the functioning of the previous management model. It is therefore appropriate to regard the current stage as a transitional one: the regulatory framework of the new system is largely in place, but its actual effectiveness will require further assessment once sufficient practical experience has been gained and the first comparable results become available.

The realisation of seized assets within the ARMA system must ensure not only the formal sale of property but also its effective economic use in the interests of the state. In the logic of asset recovery, the sale of an asset is one of the final stages, which must guarantee the preservation or maximisation of its value following seizure.

Currently, the procedure for the realisation of assets is carried out by legal entities selected on a competitive basis; the procedure for selecting such legal entities and the procedure for the realisation of assets are set out in CMU Resolutions No. 558 of 9 August 2017 ‘On the selection, on a competitive basis, of legal entities carrying out the realisation of seized assets’ and No. 719 of 27 September 2017 ‘On the Approval of the Procedure for the Realisation of Seized Assets at Electronic Auctions’ (as amended by Resolution of the Cabinet of Ministers of Ukraine No. 1250 of 14 November 2023).

The sale of assets is carried out via electronic auctions on the Prozorro.Sales platform, which is intended to ensure transparency, competition and market-based pricing. At the same time, the law imposes a number of restrictions, in particular regarding the sale of sanctioned assets and property pending a final court decision, which affects the volume and structure of assets available for sale.

Thus, an effective disposal model requires not only the existence of an electronic auction mechanism, but also the proper preparation of assets, a sufficient level of competition and the minimisation of repeated and unsuccessful procedures.

According to ARMA’s 2024 report, the Agency positions the disposal of assets as one of its key areas of work following the launch of the mechanism via Prozorro.Sales.

In its report, the Agency regards the disposal of assets as one of the most effective areas of its work and highlights the growth in revenue to the State Budget, the number of auctions held and the expansion of the practice of disposing of seized assets via the Prozorro.Sales system.

In 2024:

• 165 electronic auctions were held;
• UAH 326.3 million was received by the State Budget, of which UAH 89.7 million was in customs duties;
• 35 meetings of the commission for the selection of organisers were held, 76 tenders were announced, 49 winners were selected and 49 contracts were concluded. 

The breakdown of revenue indicates that sales are concentrated in a few categories of assets:

• 33% – potassium chloride (UAH 111.8 million);
• 27% – mineral fertilisers (89.9 million UAH);
• 15% – liquefied gas (50.8 million UAH);
• 25% – other assets. 

In 2025, ARMA reports further growth in key indicators:

• 184 auctions were held, of which 41 were successful;
• revenue to the budget totalled 411,470,197 UAH, including 161.9 million UAH in customs duties;
• 4,310 assets out of 5,322 were sold;
• a total of 7,431 assets worth 2.605 billion UAH over the entire period. 

Among the largest assets sold were:

• 29,242 tonnes of potassium chloride – 313.3 million UAH;
• the vessel Nika Spirit – 6.5 million UAH;
• ferrous metals (30 wagons) – 23.6 million UAH;
• iron ore pellets (213 railway wagons) – 24.9 million UAH;
• movable property (electronics, clothing, etc.) – 19.1 million UAH. 

Compared with 2024, ARMA increased the number of auctions held from 165 to 184, whilst budget revenues rose from 326.3 million UAH to 411.5 million UAH. At the same time, the available reporting does not allow for a full comparison of the effectiveness of auction procedures between the two years, as detailed indicators of auction success rates, repeat procedures and the level of competition were only available for 2025. Consequently, the assessment of trends is necessarily based primarily on an analysis of the structure of auctions in 2025.

An analysis of the data for 2025 reveals a more complex picture. According to official figures, only 41 out of 184 auctions (around 22 per cent) were successful. This means that the majority of procedures did not result in the sale of assets or ended without a result.

Our analysis confirms the systemic nature of this problem. Of the 184 auctions, 144 were unsuccessful and 11 were cancelled. At the same time, 84 auctions (around 46 per cent) were repeat procedures for assets that had previously been put up for sale. In fact, this amounts to approximately 100 unique lots, a significant proportion of which were relisted multiple times due to a lack of buyers .

The ratio between the potential and actual sale value is also telling. The total amount received from the sale of the lots was around 196 million UAH, whilst the combined starting value of these assets exceeded 1 billion UAH. This indicates a significant gap between the potential and actual sale value of the assets.

At the same time, ARMA does not carry out a systematic public analysis of the factors influencing the success of asset sales. Practice in 2024–2025 demonstrates significant differences between the sales results for different categories of property: individual consignments of goods, raw materials and movable assets are sold relatively successfully, whilst other lots are put up for sale repeatedly due to a lack of demand. Public reports lack an analysis of how asset characteristics, lot structure, starting price, the condition of the property or the level of market liquidity affect auction results. Under such circumstances, it is difficult to assess whether unsuccessful sales are linked to the specific characteristics of particular assets, shortcomings in their preparation for sale or limited market interest.

At the same time, ARMA’s materials indicate that sales outcomes depend to a large extent on the structure of the sales procedure itself. A significant proportion of auctions do not take place due to a lack of participants; repeat procedures are widely used; and the starting price and lot structure directly influence the final outcome. In the event of failure, the Agency employs price-reduction mechanisms, in particular by conducting English or Dutch auctions .

Thus, the practice of asset sales in 2025 indicates that the system functioned largely through repeat and adapted sales procedures following unsuccessful attempts at disposal, whilst the proportion of successful initial auctions remained relatively low. However, the available data do not allow for a similar assessment of 2024, which significantly limits the ability to compare the system’s effectiveness over time.

Furthermore, a significant proportion of the proceeds is generated by a limited number of large and liquid assets, which further complicates the assessment of the effectiveness of the disposal mechanism in relation to a broader range of seized property.

Despite the increase in the number of auctions and budget revenues, the available data indicate that the system for the realisation of seized assets continues to be characterised by a number of systemic constraints, which prevent its effectiveness from being assessed solely on the basis of financial results or the number of procedures conducted.

• Low success rate of auction procedures

One of the key problems remains the low proportion of successfully concluded auctions. According to ARMA data, in 2025, out of 184 auctions held, only 41 resulted in the sale of an asset, accounting for approximately 22 per cent of the total number of procedures. The remaining 144 auctions either did not result in the sale of assets or were cancelled, indicating a significant gap between the number of procedures initiated and the actual outcome of their conduct. Consequently, the majority of auctions fail to achieve their immediate objective – the sale of assets and the generation of revenue for the budget. 

• Recurrence of unsuccessful disposal procedures

The total figure of 184 auctions conducted by ARMA in 2025 does not mean that 184 different assets were put up for sale. The analysis carried out shows that a significant proportion of these procedures resulted from the same assets being put up for sale repeatedly following unsuccessful previous attempts at disposal. In fact, there were 133 competitive procedures and around 100 unique lots, if we exclude repeat auctions for the same properties.

It is particularly telling that 84 auctions, or almost half of all procedures in 2025, were repeat auctions. In many cases, assets were put up for sale a second, third or even more times due to a lack of bidders or the unsuccessful conclusion of previous auctions. This practice indicates that part of the system for the sale of seized assets functions not as a rapid sales mechanism, but as a protracted cycle of repeated procedures.

The repetition of auctions also points to limited initial demand for certain categories of assets. As a result, a sale often becomes possible only after the terms of sale are amended or the starting price is gradually reduced, creating a risk that assets will be sold at a value below their initial economic potential.

• Low level of competition and limited market participation

An analysis of the auctions held indicates limited competition amongst potential buyers. Only 83 bids were submitted for all successful and unsuccessful auctions in 2025. In most cases, a single bidder took part in the auction; less frequently, two. 

In certain asset categories, there is a concentration of successful bids amongst a limited group of buyers. In particular, UKRMINCHIM Trading House LLC secured eight successful bids during the sale of potassium chloride consignments. This pattern of participation indicates insufficient competition in the market for seized assets and limits the potential for achieving the maximum market price.

• Inadequate preparation of assets for sale

The practice of selling individual assets shows that the quality of lot preparation directly affects sales outcomes. Such factors include the accuracy of the asset valuation, the completeness of information about the asset, the proper structuring of the lot, and its legal readiness for sale. In some cases, it was precisely problems during the preparatory stage that caused delays in sales or the need to repeat the procedures. This indicates that the effectiveness of a sale depends not only on market demand, but also on the quality of the preparatory work prior to the auction.

• Lack of a systematic analysis of the causes of unsuccessful sales

Despite the significant number of unsuccessful auctions, ARMA does not publish a systematic analysis of the reasons for their failure. The reports lack aggregated data on the impact of the starting price, asset category, lot structure, level of competition or other factors on the results of the auctions. Consequently, it is impossible to determine which specific categories of assets are sold successfully, which face the greatest difficulties, and which management decisions require adjustment.

Individual cases suggest that the reasons for unsuccessful or cancelled sales procedures may be considerably broader than a mere lack of demand for the asset. For instance, during the sale of 494 plots of land in Zakarpattia Oblast, ARMA refused to sign the auction results protocol and conclude the sale and purchase agreement following a verification of the winning bidders. According to the Agency’s official information, the details obtained indicated signs that the winners were linked to the owner of the seized assets. At the same time, such cases are reported mainly in individual news items and do not form part of a systematic analysis of the risks affecting the results of asset sales. Under these circumstances, it is difficult to assess the scale of such situations and their impact on the overall effectiveness of the system for selling seized property.

• Limited ability to assess the system’s effectiveness

Despite more detailed data for 2025, the reporting system still does not allow for a comprehensive assessment of the effectiveness of asset sales over time. The 2024 report contains mainly financial indicators and the number of procedures carried out, but does not provide the means to assess the proportion of successful auctions, the level of competition or the scale of repeat sales. The lack of standardised reporting indicators across years significantly limits the ability to independently assess the development of the asset disposal system and the effectiveness of the reforms implemented.

Furthermore, despite updates to the legislation governing asset management, as at the date of this report, asset sales continue to be conducted predominantly within the procedural framework established prior to the latest ARMA reform. This means that most of the identified issues remain relevant even after the legislative changes have been finalised, and their resolution will depend on the further development of practices in applying the updated legislation.

If current approaches to asset disposal are maintained, there is a risk of a further disconnect between formal performance indicators and the actual effectiveness of the system. An increase in the number of auctions or budget revenues does not in itself guarantee an improvement in the effectiveness of asset disposal, particularly if a significant proportion of these results is generated by a limited range of liquid assets or the repeated use of the same sales procedures.

A separate risk relates to the loss of the economic value of assets due to their prolonged presence in the disposal system. The longer an asset remains unsold and is repeatedly put up for auction, the higher the likelihood of its depreciation, a decline in its market attractiveness, or its sale on terms less favourable to the state.

The persistence of low levels of competition at auctions also creates a risk of limited market-based pricing. In the absence of a sufficient number of participants, the auction mechanism loses one of its key advantages – the ability to determine the maximum market value of an asset through competitive bidding.

Furthermore, the lack of a systematic analysis of the causes of unsuccessful auctions and of standardised performance indicators complicates management decision-making and the adjustment of asset disposal practices. As a result, certain systemic problems may persist over a long period without a proper assessment of their impact on the overall effectiveness of the system.

It would be advisable to expand the system for assessing the effectiveness of asset sales by supplementing financial indicators with metrics that characterise the efficiency of the auction procedures themselves. In particular, public reporting could include information on the proportion of successful auctions, the number of repeat procedures, the level of competition among participants, the ratio between the starting and final sale prices, and the proportion of assets sold at the first attempt.

Particular attention should be paid to preparing assets for sale. The quality of the valuation, the completeness of information about the asset, the proper structuring of lots and the timely removal of legal restrictions directly influence the interest of potential buyers and the results of auctions.

To increase competition in auctions, it is advisable to strengthen communication with the market and ensure more predictable and transparent conditions for participation in auctions. This applies in particular to distressed assets, for which the pool of potential buyers is limited.

It would also be advisable to introduce a regular analysis of the reasons for unsuccessful auctions, followed by the publication of summarised results. This would make it possible to assess the impact of various factors on sales outcomes and to adjust asset sale practices in a timely manner.

To enhance transparency, it would be advisable to report separately on proceeds from asset sales, customs duties, the results of repeat auctions, and the reasons why certain categories of assets remain in the sales system for extended periods.

In 2024–2025, the asset disposal mechanism continued to develop and ensured growth in revenue to the state budget. Disposal via the Prozorro.Sales system became established practice, and the number of auctions held and the volume of funds received showed positive trends.

At the same time, the available data indicate that this quantitative growth was not accompanied by a corresponding improvement in the efficiency of the procedures. A significant proportion of auctions remained unsuccessful, repeat procedures played a substantial role, and the level of competition in many auctions remained limited. Furthermore, the absence of a standardised reporting system between 2024 and 2025 prevents a full assessment of the performance trends of the asset disposal mechanism.

Thus, the development of asset realisation during the period under review can be assessed as moderate. Despite positive financial results and the functioning of the auction mechanism, further improvements in efficiency require not so much an increase in the number of procedures as an improvement in their effectiveness, competitiveness and transparency.