Asset recovery mechanism, chapter IV of UN Convention against Corruption, is composed of prevention system,directive recovery system,indirective recovery system, assets return and disposal system .This mechanism offers us a general way to deal with the recovery of assets derived from corruption, meanwhile, the agreement countries have the responsibility to establish or better domestic law according to the rules of UN Convention. This thesis is focused on analyzing how to minimize the difference between Chinese law of asset recovery and the mechanism set by the UN Convention through the establishment and bettering of prevention system , independent civil system, criminal trial by default system within the mechanism of asset recovery, freezing and seizure of property of crime system, recognition and enforcement of foreign judgement system, and cost compensation and benefit share system so that the loss caused by corruption could be minimized. |