Starting in July 2023, the Asset Tracing and Management Agency began implementing the key recommendations set forth in the Facility Plan—a strategic document agreed upon with international partners in May of that year. This step served as a test of the institution’s ability to transform in line with the expectations of the European community, which is closely monitoring the reform of Ukraine’s law enforcement and anti-corruption sectors.
ARMA in Action: A New Stage of Transformation
Particular attention is being paid to the role of the agency’s head
of the agency, as it is the leader who sets the pace and quality of change and shapes the agency’s institutional culture. Whether the Agency becomes an effective tool for asset recovery and transparent asset management, or remains in the shadow of the high-profile scandals of past years, depends directly on the management decisions of ARMA’s top official. The successful implementation of the Facility Plan demonstrates not only administrative will but also political readiness for the far-reaching reforms demanded by both Ukrainian society and international partners.
ARMA’s official reports, the Cabinet of Ministers’ resolutions approved at its initiative, as well as record-breaking revenues to the state budget—over 12.37 billion UAH in 2024 and already more than 3 billion in 2025—attest to a systemic shift in the agency’s operating model. For the first time in many years, seized assets are not simply being held in storage or lost in the shadows—the funds generated from their management are being directed toward supporting the Armed Forces of Ukraine, meaning they are working for the benefit of the state and society.
These results are a direct consequence of breaking away from the old, corrupt practices that for decades marginalized the institution responsible for managing seized property. And just as importantly, the model that has been built is so robust that it can no longer be dismantled “quietly,” without changes to the law. That is precisely why, under the guise of “reform,” attempts have begun to undermine these achievements: to replace transparent competitive selection processes with subjective “personnel roulette,” and to restore informal control over assets through mechanisms that de facto entail the privatization of state functions.
This refers to the parliamentary bill “On Amendments to Certain Legislative Acts of Ukraine Regarding Strengthening the Institutional Capacity of the National Agency of Ukraine for the Identification, Tracing, and Management of Assets Derived from Corruption and Other Crimes, and Improving Asset Management Mechanisms,” No. 12374-d, which is causing concern among experts and poses significant risks.
Legislative Risks and Attacks Under the Guise of “Reform”
The essence of the proposed changes has not gone unnoticed by the professional community: according to the conclusions of the Office of the Prosecutor General, the Specialized Anti-Corruption Prosecutor’s Office, the Ministry of Finance, and the relevant parliamentary committees on budget and law enforcement—this draft law poses a risk to the entire legal framework for combating economic crimes. And unless amendments are made to the Code of Criminal Procedure, the mechanisms outlined in the “reform” will remain nothing more than a declaration—political, but not legally enforceable.
The attempt to push the bill forward through a public partnership—between the authors of the “reform” and business representatives whose assets are under seizure—ended in an expected fiasco. Neither media headlines nor appeals to G7 ambassadors with grandiose promises of “transparency” could conceal the true goal—the creation of a convenient mechanism for returning assets of dubious origin. International partners saw through the manipulation: Bill No. 12374-d received yet another critical remark, this time regarding an attempt to interfere with the asset declaration requirements for public officials—an issue entirely unrelated to ARMA’s activities.
The legislative process, which should be based on adherence to constitutional procedures, has turned into a display of arbitrary legal action. The Verkhovna Rada’s Main Anti-Corruption Committee, in pushing this bill forward, has violated at least 14 articles of the Constitution. And most tellingly, under the guise of “ARMA reform,” changes are being proposed that in fact constitute direct interference in the jurisdiction of the National Agency for the Prevention of Corruption.
This blurring of functions and institutional roles is not a mistake but a deliberate move aimed at obscuring accountability and weakening institutional oversight. The professional legal community has repeatedly emphasized that any reform aimed at systemic and sustainable effectiveness cannot be based on the substitution of concepts and the manipulation of jurisdiction.
Political Motives and Financial Interests Behind the Reform
The legal nihilism we have been observing within the walls of parliament over the past three months has a thoroughly pragmatic basis—the desire to secure the next tranche of financial aid from the European Union. The professed reformist zeal of some members of parliament strangely intensifies precisely when millions of euros are at stake. After all, as is well known, funds from USAID have already been successfully “absorbed.” Now—a new financial horizon, and new declarative initiatives.
In this situation, ARMA’s position remains steadfast and unequivocal: the law must be effective, and accountability must be real. The agency has clearly stated that its mission is to enforce the law, not to serve as a tool for political experiments or donor-driven spectacles. Substituting substance with rhetoric does not work when the effectiveness of mechanisms is measured by results, not by the number of slogans.
And that is precisely why the initiatives that have been developed and
submitted by ARMA over the past 1.5 years have become the focus of public attention. It’s not just experts or journalists who are talking about them—they’re already familiar to every ordinary citizen. Because transparency, accountability, and anti-corruption effectiveness aren’t just concepts for memorandums; they’re what society demands. And today, that demand is particularly loud.
The enemy’s assets must work toward victory
The principle that must now become the cornerstone of state policy regarding the management of seized assets is simple and obvious: everything that belongs to the enemy must be used against the enemy. This is not merely a matter of justice or morality—it is a matter of effectively securing resources for the country during wartime.
However, for this principle to work, a clear and unambiguous legal framework is needed—one that does not allow anyone to hide behind fictitious structures or procedural loopholes. In particular, the management of corporate rights must be unblocked, as it is currently often stalled by the formal requirement to obtain permission from the owner—an individual who is directly or indirectly linked to the aggressor state.
The paradox is this: the state has all the legal grounds for seizure, confiscation, and transfer of management, but is held back whenever “voluntary participation” by the owner is required. And this absurdity calls into question the effectiveness of law enforcement. That is precisely why a systematic solution to such problems is no longer a matter of choice, but a matter of national security and survival.
Accountability and the rule of law—the key to victory
Despite the existence of official conclusions from key institutions—the Office of the Prosecutor General, the Specialized Anti-Corruption Prosecutor’s Office (SAPO), the Ministry of Finance, and relevant parliamentary committees—the parliamentary committee responsible for reviewing draft laws in the field of anti-corruption policy has, over the course of a year and a half, failed to place on the agenda any documents that could systematically resolve the problems in ARMA’s operations and ensure the full functioning of the mechanism for managing seized assets.
It seems that it was not up to Parliament, but to the President, to put an end to this saga. The head of state’s resolute decision sent a clear signal: reform cannot be held hostage to sabotage, procrastination, or attempts at manual control. Ukraine’s recent history is being written right now—not in speeches or slogans, but in the daily work of those who are truly committed to effective public administration and transparent processes.
And every time we see delays or blockages, we should not look for technical reasons or bureaucratic explanations. Usually, there are ulterior motives behind this. Because where there is political will, decisions are made quickly. Where there is none, the passage of laws turns into an endless game played in the interests of those who fear transparency.
True rule of law is not just a slogan from European reports, but the state’s daily ability to act fairly, decisively, and within the law. This is a real test of our maturity as a nation and of the identity of the Ukrainian people, who have the full and unquestionable right to compensation for the damages inflicted upon them.
Ukraine cannot afford the luxury of being weak when it comes to justice. The enemy has no right to profit on Ukrainian soil while the war rages on and our citizens are dying every day. Russian assets, frozen and seized in accordance with the law, must be used against the aggressor—and first and foremost to strengthen the defense capabilities of our army.
The political will is there. The President consistently and clearly demonstrates a resolute stance on protecting the state’s interests, preventing the resurgence of old corrupt practices under the guise of “reforms.” In this context, ARMA is not merely an agency but a key implementer of state policy: a tool for strengthening our capacity as a state in times of major war.
Now it is up to Parliament. The law must be enforced. And the state must prevail.
Author: Oleksiy Shevchuk, Attorney and Partner at Barristers
Source: https://zib.com.ua/ua/167116.html