18 June marks a year since the law reforming the Asset Recovery and Management Agency (ARMA) was passed. It is time to take stock of what has changed since the new law and what of interest we found in ARMA’s 2025 report.
The need to streamline the Agency's work is nothing new: experts and international partners alike had long pressed for it. The new law was therefore meant to bring about a systemic transformation of the very logic of managing seized assets.
A change of approach is visible in the Agency’s 2025 report, though one must bear in mind that some of its data reflect work done under the old rules, while some captures the gradual changes that have followed the reform.
At the same time, as we have written before, the reform itself has not yet been fully implemented: key secondary legislation was adopted late, and the new mechanisms for selecting managers through Prozorro are only beginning to be rolled out for complex assets.
Even so, this first report still provides the most up-to-date picture of how exactly the Agency works, so let us look at the data through the prism of the same questions we asked last year.
Identification and tracing: more requests, fewer items found
In 2025, ARMA received 9,468 requests to identify and trace assets—a 20 percent increase on 2024 (7,865).
Yet the number of assets actually identified fell across a range of categories. Some 29,000 plots of land were identified, against 107,000 in 2024—a figure we flagged at the time as an anomaly. By contrast, the figures rose for identified funds (36.5 billion hryvnias against 8.3 billion), for corporate rights (58.5 billion against 35.9 billion) and especially for virtual assets (1.29 million USDT against 2,400 USDT), a more than 530-fold increase.
A fundamentally new section of the report is the one in which ARMA publicly acknowledges the structural gap between traced and seized assets. The share of property traced by the Agency that was subsequently seized comes to just 2 percent. The report explains, in particular, that the information on traced assets that ARMA prepares cannot be used as evidence in criminal proceedings.
Separately, the Agency points out that some tracing requests come in proceedings where no confiscation—or scope for special confiscation—is envisaged at all. And information on traced assets is used by the prosecution within the framework of Article 93 of the Criminal Procedure Code of Ukraine, which governs purely the rules for gathering evidence. In other words, in certain cases ARMA functions as a property records service for law enforcement bodies.
In addition, in 2025 the Agency sent 639 international requests, against 383 in 2024 (+66%). Impressive as they may seem, these figures raise the question of the quality of each request and of the effectiveness of the institution’s foreign track as a whole. ARMA’s report does spell out that, abroad, 366 units of real estate, 88 vehicles, $5.9 million and corporate rights worth the equivalent of 924.86 million hryvnias were identified. But how much of this has been seized, and which of these decisions have been recognized by foreign competent authorities, is unknown.
Of course, such decisions by foreign actors do not depend on ARMA alone; but to assess the state of asset recovery (which is one of the Agency's functions), there is too little information on the seizure of the relevant assets abroad.
Asset management: more new contracts, but the main revenue comes from the old ones
Last year we wrote that ARMA had concluded only seven management contracts against 33 announced tenders. For 2025, we now have 40 management contracts under 38 court rulings. Formally this is a breakthrough, but alongside it we see 27 contracts still running from previous years—and it is these that remain the main source of revenue for the state budget.
A single contract—with Ukrnafta, over the assets of Ukrnaftoburinnia, concluded back in June 2023—brought in 1.074 billion hryvnias of budget revenue out of 1.54 billion from management contracts in total. In other words, roughly 70 percent of the annual profit figure is generated by a single asset. Meanwhile, all 38 new contracts of 2025 account for just 2.5 percent of revenue (38.7 million hryvnias).
The asset sale figures for 2025 are likewise contradictory. On the one hand, the Agency organized 184 auctions, of which only 41 proved successful (around 22%). That is to say, almost four in five auctions produced no result. This calls for a separate explanation, both as to the quality of how the lots were put together and as to the starting prices and the attractiveness of the assets.
The key thing that did not make it into the report is that, by the time of its publication, the new mechanisms for selecting managers through Prozorro had still not been launched, even though they were due to be up and running by 30 January 2026. This means that the transfer of assets to managers under the new rules is, on the whole, significantly delayed.
Oversight of managers: a quantitative increase, but questions of quality remain
In 2024, ARMA carried out only ten on-site inspections of managers—one of the key figures we criticized. For 2025, we now have 38 on-site inspections and 348 desk reviews, 386 oversight measures in all. The results: 27 orders issued to managers and five established instances of improper management.
This is a marked improvement in terms of trend. But in absolute terms, 38 on-site inspections set against the 34,000 assets worth 10.7 billion hryvnias that ARMA has placed under management in all is a modest figure.
Moreover, the report does not reveal how exactly the inspection results were interpreted: how many orders led to an actual change in a manager’s conduct, how many contracts were terminated for ineffectiveness. And the scandalous KAMparitet case, in which shopping centers were sublet at prices three times the declared income, is not mentioned in the report at all—even though it was discussed separately at the anti-corruption committee, and in 2026 the Agency has already confirmed the violations and announced its intention to terminate its agreements with the company.
Inventory: the final count of assets under ARMA’s management is finally established
The transitional provisions of the new ARMA law obliged the body, within six months, to identify all the assets transferred to its management before the law took effect. The Agency reports that, following a comprehensive inventory, its records cover 60,274 assets, of which 20,753 have high management potential. This also includes assets being prepared for tender procedures or already identified as attractive for transfer to management and sale.
At the same time, the Agency still does not use the term “asset pool,” which would make it possible to understand how many units of property actually form part of an operating business that could be subsumed under that concept. In practice, this means that it is quite hard to work out from the report how many economically attractive businesses are hidden behind the figure of 20,753 asset units.
In 2025, 1,703 assets were transferred to managers under contract, while over all the years ARMA has transferred 34,062 assets to managers in total. The valuation of these 1,703 assets is 5.3 billion hryvnias, while the valuation of all assets is 10.7 billion. It turns out that the value of the nearly 5 percent of assets placed under management in 2025 amounts to roughly half of the total value. One hypothesis here might be that in previous years it was largely low-value assets that were placed under management.
In all, the body of assets in respect of which the Agency has the power to take any action stands at 94,000 units. Of these, 34,000 have already been transferred to managers under contract (1,703 in 2025), and 60,000 have not been transferred (20,000 of them with high management potential).
A separate problem has been the handling of “complicated” assets: of 100 approaches ARMA made to prosecutors about being unable to manage them effectively, replies came to only 32, of which the question was resolved favorably in just five. That is, 95 percent of the cases in which ARMA has already deemed an asset problematic to manage remain unaddressed once the prosecution is brought in. And this problem should be solved by amending the Criminal Procedure Code of Ukraine, as we have stressed before.
* * *
Over the past year, the volume of processes inside ARMA has grown substantially. The Agency is drafting secondary legislation, conducting an inventory of assets, tracing them and shaping recovery policy. Not every task has been accomplished, but the progress is visible.
Even so, in watching ARMA’s results, we should like to see real results on the effectiveness of asset recovery. And that can be traced, in particular, by setting side by side the results of tracing, seizure, effective management and confiscation of property. In addition, from the data available in the report it is unclear how exactly the new system for selecting managers has worked, since not a single such auction has taken place since the law was passed. And the management contracts collected in the report were concluded under the old procedures.
That is why we see the key task for ARMA today as a change in the very logic of tracing and managing property. In our view, the next report should demonstrate not only the volume of work done but also concrete achievements at the scale of the whole system. All the more so since it will no longer make sense to point to the old rules.