Effective asset recovery cannot always depend on a criminal conviction: suspects may die or abscond, while illicit proceeds may be transferred to estates or third parties. Yet civil claims based on ownership, restitution or compensation must be distinguished from statutory non-conviction-based confiscation. This article argues that Hong Kong’s equitable remedies offer Vietnam a useful but limited comparative lesson: civil proceedings can pursue identifiable bribery benefits where a recognised legal entitlement and a sufficient property nexus are established, but they do not themselves create a general power to confiscate assets of suspected illicit origin. Using doctrinal analysis and functional comparison, the article examines Attorney General for Hong Kong v Reid, the civil proceedings concerning Hon Sum’s estate, Hong Kong’s statutory confiscation framework, and Vietnam’s criminal-procedure rules and public-interest litigation pilot under Resolutions No. 164/2024/QH15 and No. 205/2025/QH15, read alongside the United Nations Convention against Corruption. The analysis finds that Reid followed a criminal conviction, while the Hon Sum proceedings ended in an out-of-court settlement, neither establishes a general civil-forfeiture regime. Resolution No. 205/2025/QH15 may facilitate claims to protect defined public interests, but only within its statutory scope and where a substantive cause of action exists. The article therefore recommends a separate civil asset-recovery framework specifying claimant standing, recoverable property and its connection to corruption, evidentiary standards, judicially controlled interim measures, coordination with criminal proceedings, and protection for bona fide third parties.