How ARMA Communicates Its Reform: A Content Analysis of the Agency’s Social Media

The need for a comprehensive reform of the Asset Recovery and Management Agency (ARMA) is becoming increasingly urgent. This demand is reflected in the Ukraine Facility Plan, the Memorandum between Ukraine and the IMF, and the European Commission’s latest report on Ukraine’s EU accession prospects.

At the same time, the Agency’s own position on the reform remains somewhat unclear. Throughout their tenure, ARMA’s leadership emphasized the need to introduce legislative changes to improve the Agency’s operations. However, from the outset, there was little clarity about how comprehensive these changes should be—or what exactly they would entail.

From the outset, ARMA supported Draft Law No. 12374, prepared by the Cabinet of Ministers. However, members of the public and several MPs expressed concerns about this version of the reform, particularly due to the lack of essential provisions to improve transparency in the management and sale of seized assets. As a result, MPs proposed alternative drafts, one of which, authored by Oleksii Movchan, Anastasiia Radina, Yaroslav Zheliezniak, and others, was adopted by Parliament as a basis on February 12. Although this version of the reform included significant improvements, it still required further refinement, which later became the focus of collaborative work between the authors and the expert community.

At the same time, ARMA responded cautiously to the draft law adopted in the first reading, and the Agency’s communication regarding its own reform gradually began to shift.

Transparency International Ukraine experts conducted a content analysis of ARMA’s communications to examine how the institution presents its own reform, how the Agency’s leadership’s stance on legislative changes has evolved, and how well-founded its current position is regarding Draft Law No. 12374-d, which is under parliamentary consideration. The analysis covered the period from February 1 to April 16, 2025, focusing on ARMA’s Facebook page—its primary platform for communication on social media.

Brief conclusions:

• The main message in the Agency’s communication about the reform is not the need for systemic change, but rather the claim that such changes have already been underway for nearly two years, since the new ARMA leadership took office
• During the period under review, the Agency’s public communication made no mention of ARMA’s failures or missteps since June 2023, nor of any efforts made to address or learn from them
• Throughout the entire study period, ARMA publicly supported only the government’s version of Draft Law No. 12374. In contrast, the Agency’s communication regarding Draft Law No. 12374-d, adopted in the first reading, focused solely on its shortcomings, without acknowledging any of the document’s positive aspects
• Since February 2025, ARMA’s attitude to Draft Law No. 12374-d has shifted from cautious to categorically negative, with a significant portion of the Agency’s arguments based on an outdated version of the draft
• At present, ARMA is firmly opposed to the adoption of the current version of the draft law. In all public communications, the Agency consistently advocates for the approval of the government’s version, while its position on the version adopted by the relevant committee has shifted—from calls for revision to outright claims that the draft is fundamentally corrupt.

How the tone of ARMA’s communication changed on the issue of reform and legislative changes 

In recent months, ARMA’s reform has become one of the central themes in their communication. Between February 1 and April 16, 2024, ARMA published 176 posts on its Facebook page. Of these, 44 posts—25% of the total—referred in some way to the planned reform and related legislative changes.

At the same time, the intensity of ARMA’s communication on the reform issue fluctuated, with certain periods—such as February 26 to March 14 and April 2 to April 11—showing a complete absence of references to the reform in the Agency’s messaging.

ARMA’s main messages on the reform and Draft Law No. 12374-d from February 1 to April 16, 2025 (with approximate mention counts, as many messages were repeated within a single post):

• Since June 2023, ARMA has been successfully undergoing transformation and reform without donor funding or external assistance (mentioned at least 21 times)
• ARMA was not involved in the development of Draft Law No. 12374-d — “Nothing about ARMA without ARMA” (mentioned at least 12 times)
• Draft Law No. 12374-d contradicts European standards and jeopardizes European integration (mentioned at least 8 times)
• Draft Law No. 12374-d threatens anti-corruption bodies and the entire anti-corruption system (first mentioned on April 15, then repeated at least 5 times)
• Draft Law No. 12374-d is described as corrupt (first mentioned on April 15, then repeated at least 5 times)
• Draft Law No. 12374-d is said to violate 14 articles of the Constitution of Ukraine (first mentioned on April 15, then repeated at least 4 times)
• Draft Law No. 12374-d is said to promote functions that fall outside ARMA’s typical mandate (first mentioned on April 11, then repeated at least 4 times)
• Draft Law No. 12374-d is said to have taken on a political connotation (first mentioned on April 11, then repeated at least 4 times).

Overall, ARMA’s communication on the reform issue, reflecting shifts in tone, can be divided into four distinct periods:

1. February 1 to February 12 — the period before the adoption of Draft Law No. 12374-d, an alternative to the government’s version, as the basis
2. February 13 to March 26 — leading up to the release of the second comparative table for Draft Law No. 12374-d, as approved by the Committee
3. March 27 to April 16 — the period covering ARMA’s communication on the final version of the draft law, which the Committee submitted to Parliament for the second reading and adoption as a whole.

We reviewed all ARMA posts published during these periods and will further examine their key features.

ARMA’s reform-related posts from February 1 to 12

During this period, ARMA published three posts on its Facebook page that addressed the issue of the Agency’s reform. Each post focused on advocating for parliamentary adoption of the government’s Draft Law No. 12374. Alternative proposals were not analyzed in the Agency’s public communications and were mentioned only briefly and selectively.

ARMA’s main messages during this period:

• Since June 2023, ARMA has been successfully undergoing transformation and reform without donor funding or external assistance
• ARMA has already been transformed
• ARMA calls on MPs to support the government draft law within the framework of the Ukraine Facility Plan.

ARMA’s reform-related posts from February 13 to March 26

During this period, the Committee, in collaboration with representatives of state institutions and the expert community, worked on revising and amending Draft Law No. 12374-d, which had been adopted in the first reading.

At the same time, ARMA’s stance on the draft law was still taking shape throughout this period—and gradually shifted toward a categorically negative position.

ARMA’s main messages during this period:

• Since June 2023, ARMA has been successfully undergoing transformation and reform without donor funding or external assistance
• ARMA has already been transformed
• ARMA was not involved in the development of Draft Law No. 12374-d — “Nothing about ARMA without ARMA”
• Draft Law No. 12374-d contradicts European standards and jeopardizes European integration.

ARMA’s reform-related posts from February 27 to April 16 

Over the course of this period, ARMA’s attitude toward Draft Law No. 12374-d shifted into a categorically negative position. The Agency does not support the draft recommended by the Committee in any way and begins to assemble a team of its opponents.

The list of key messages presented in earlier sections was expanded during this period with new, louder, and more provocative statements. ARMA’s stance on the draft law shifted to a categorically negative one, often lacking strong or well-substantiated arguments. Most of these messages were first introduced on April 11 in a post announcing a public event organized by ARMA to discuss the draft law. Subsequently, during and after the event held on April 14, 2025, the Agency repeatedly reiterated these points.

ARMA’s main messages during this period:

• Since June 2023, ARMA has been successfully undergoing transformation and reform without donor funding or external assistance
• ARMA has already been transformed
• ARMA was not involved in the development of Draft Law No. 12374-d — “Nothing about ARMA without ARMA”
• Draft Law No. 12374-d contradicts European standards and jeopardizes European integration
• Draft Law No. 12374-d violates 14 articles of the Constitution of Ukraine
• Draft Law No. 12374-d threatens anti-corruption bodies and the entire anti-corruption system
• –       Draft Law No. 12374-d promotes functions that fall outside ARMA’s typical mandate
• –       Draft Law No. 12374-d has taken on a political connotation
• –       Draft Law No. 12374-d is corrupt.

Below is a list of all relevant posts, including quotes that highlight the key features of ARMA’s communication (original spelling and grammar preserved).

Conclusions 

As a result of the content analysis of ARMA’s Facebook page, we found that the Agency’s attitude toward the overall reform, and particularly toward Draft Law No. 12374-d, currently under parliamentary consideration, evolved over time, becoming increasingly manipulative in tone.

In this analysis, we identified the following key features of ARMA’s communication on the reform topic:

• Throughout the entire period under review, the main message in ARMA’s communication was not advocating systemic reform, but rather the claim that such changes have already been underway for nearly two years—this was the most frequently repeated thesis in the Agency’s posts
• The Agency’s public communication for the said period made no mention of ARMA’s failures or missteps since June 2023, nor of any efforts made to address or learn from them
• Throughout the study period, ARMA continued to support only the government’s version of Draft Law No. 12374, which was rejected by Parliament back in February 2025, and consistently insisted on its further consideration. In its public communication about Draft Law No. 12374-d, which was adopted in the first reading, the Agency focused exclusively on the draft’s shortcomings—without acknowledging any of its positive aspects
• The analysis revealed that ARMA frequently shifted the focus of its communication, at times contradicting its own previously stated positions. The only message that remained consistent was ARMA’s claim that the Agency has already been reformed since 2023. Such an approach to communication by a state institution can hardly be considered constructive.
• Since February 2025, ARMA’s attitude toward Draft Law No. 12374-d has gradually shifted from cautious to categorically negative. Moreover, a significant portion of the Agency’s arguments is based on an outdated version of the draft, as evidenced by the finalized communication theses presented following the public discussion organized by ARMA on April 14.
• As the tone of ARMA’s publications on Draft Law No. 12374-d became increasingly negative, the volume of such communication also grew. By the end of the study period, the number and frequency of posts related to the draft law significantly exceeded those about ARMA’s core activities. This suggests a lack of balance in the Agency’s communication, both in terms of providing comprehensive information about its activities and maintaining objectivity in its messaging. Such an approach falls short of public expectations regarding general approaches to responsible communication by public authorities.
• Today, ARMA firmly opposes the adoption of the current version of the draft law. Throughout its public communication, the Agency consistently advocates for the adoption of the government’s version, while its stance on the version approved by the relevant committee has shifted—from initial calls for revision to claims that the draft violates the Constitution of Ukraine, threatens European integration and anti-corruption institutions, and would enable the return of corruption schemes.

Based on the findings above, it can be concluded that ARMA’s communication over the study period has become increasingly manipulative. The shift in tone—from cautious to overtly negative—suggests that the Agency is promoting a firmly categorical and ungrounded position in its public messaging. Moreover, the Agency’s response to comments from representatives of other state bodies and the public suggests that ARMA’s leadership is not open to criticism directed at the institution.

ARMA’s manipulative and selective communication regarding Draft Law No. 12374-d suggests that the Agency has focused its entire communication strategy on discrediting this particular version of the draft. Despite the positive changes it contains, ARMA’s messaging implies that the draft offers no benefits for the management or sale of seized assets, or for the Agency itself. This position contradicts the assessments and feedback provided by various state bodies and members of the expert community.

You can view the full analysis of all ARMA posts related to Draft Law No. 12374-d in the Ukrainian version of this research.

This analysis was prepared by:

Head of the department:

Kateryna Ryzhenko, Deputy Executive Director of Transparency International Ukraine for Legal Affairs

Authors of the research:

Viktoriia Karpinska, Editor of Transparency International Ukraine

Pavlo Demchuk, Senior Legal Advisor at Transparency International Ukraine