Asset Recovery in Corruption Cases After Criminal Conviction: Experiences from The United Kingdom and Singapore with Implications for Vietnam

Asset recovery following criminal conviction plays a significant role in anti-corruption policy, aiming to deprive offenders of illicit benefits and to remedy losses suffered by the State. The present article maintains that the main difficulties of post-conviction asset recovery (PCAR) in Vietnam do not stem solely from shortcomings in legal provisions, but also from limitations in early asset preservation (EAP) prior to the final effectiveness of criminal judgments. Comparative experience from the United Kingdom and Singapore suggests that effective recovery mechanisms rely on assessing overall criminal benefits together with early asset-preservation measures. Hence, it is suggested that legal reform in Vietnam should prioritise procedural mechanisms that enable EAP and strengthen enforcement coordination. These findings help clarify how OCAR mechanisms may operate effectively across different legal traditions.