The Commission for Independent External Assessment of ARMA’s Effectiveness has approved and published the audit criteria and methodology. The document sets out the areas, criteria, and indicators by which the Agency’s work will be assessed — and what could become grounds for dismissing its head.
The Asset Recovery and Management Agency has never undergone an independent external evaluation (audit) of its effectiveness. Before the ARMA reform law was passed, the model for forming the commission was too complex and carried constitutional risks. All that time, questions about the Agency’s work kept piling up without quality answers.
So the updated legislation set out new approaches to the audit. These match the approaches used at the NABU and the SAPO — which is, without doubt, a positive development.
On January 28, 2026, the Cabinet of Ministers accordingly approved the membership of the Audit Commission under the new requirements.
What is reviewed, and for what period
The assessment covers the period from January 1, 2023, to May 31, 2026. The commission may also draw on information outside that window if it considers it important.
It reviews all of ARMA’s legal duties and activities, including its organizational, operational, and institutional conditions.
The commission will assess ARMA across five areas, each carrying a different weight in the final score:
Public governance (20%)
This examines whether the Agency has internal policies and regulatory documents, standards of integrity and ethical conduct, internal control and audit functions, systems to detect and respond to violations, transparency of operations, competent leadership, and safeguards against the misuse of resources.
Interagency cooperation, stakeholder engagement, and operational independence (15%)
This assesses whether ARMA operates free of improper influence, cooperates effectively with other bodies and foreign partners, has proper access to electronic databases and registers, and complies with data protection standards.
Asset detection and tracing (25%)
The key questions: whether ARMA responds to investigators’ and prosecutors’ requests on time, whether it provides access to the necessary databases, what share of tracing efforts leads to the actual seizure or confiscation of assets, and whether requests and results are properly recorded.
Asset management (25%)
This reviews the entire management cycle: from taking an asset on to its sale, return, or reuse. Separately, it covers preserving the economic value of assets, oversight of managers, the timeliness and transparency of sales, management of foreign assets, and participation in asset-sharing agreements.
Unified State Register of Seized Assets (15%)
This assesses whether the register meets legal requirements, the completeness and accuracy of its statistics, the security of the system, its accessibility to designated users, and whether resources are sufficient to maintain it.
The scope, methodology, and criteria of the audit are thus comprehensive enough to assess the Agency’s work properly and pinpoint the areas that need serious attention.
The final score is calculated as the average across all criteria within each area (all criteria carry equal weight), multiplied by the area’s weight. Based on the results, ARMA receives one of four ratings:
- high — 85–100 points;
- substantial — 70–84 points;
- moderate — 50–69 points;
- low — 0–49 points.
The report will be considered adopted only on a unanimous vote of all commission members.
What comes next
The commission aims to adopt the report by August 31, 2026. It will then be published on the Cabinet of Ministers’ website within five days.
A finding that ARMA is ineffective, or that its head has improperly performed their duties, is grounds for terminating the head’s powers. The Agency currently has no permanently appointed head, so the commission has developed an approach to the criteria for improper performance of duties by the future head — these will be included in the final report. The criteria will rest on the same assessment areas, criteria, and indicators as the overall evaluation of ARMA’s effectiveness; that is, improper performance by the head will be judged through the lens of the Agency’s actual results, not merely formal violations.
The scope, methodology, and criteria of the audit are thus comprehensive enough to assess the Agency's work properly and pinpoint the areas that need serious attention.
