Similar in Their Differences: Transnational Legal Processes Addressing Money Laundering in Brazil and Argentina Maira Machado The purpose of this article is to provide a comparative analysis of the transnational legal processes that Brazil and Argentina underwent to address money laundering. The article discusses the interaction between the Financial Action Task Force (FATF) norms and a number of changes both countries have experienced in the last decade. The comparison focuses on the three central pillars of the anti-money laundering order (AMLO): criminalization, administrative obligations imposed on the financial sectors, and the creation of a financial intelligence unit. Building from the analytical framework developed by Shaffer (2011), the evidence gathered in this study illustrates different dimensions of state change and highlights the main challenges to assess the effectiveness (output legitimacy) of transnational legal orders empirically. INTRODUCTION A decade ago Brazil and Argentina were invited to join the Financial Action Task Force (FATF), which previously was a select club of Organisation of Economic Coop- eration and Development (OECD) countries. At that time, the two countries shared very similar positions regarding foreign interests in the implementation of anti-money laundering norms and were both taking the first steps toward compliance with inter- national standards. Almost ten years later, Brazil is the first Latin American country to assume the presidency of FATF, and Argentina is facing one of the worst evaluations for a FATF member country. These different trajectories raise questions on the role played by membership in transnational legal processes. Relying on the comparison of these processes in Brazil and Argentina, this article contends that membership in interna- tional standard-setting bodies has only limited implications for state change. Never- theless, membership has been dominating the debates regarding the legitimacy of the transnational legal order to address money laundering. This article argues that full membership as a guarantee of representation (input legitimacy) and participation in the decision-making process (throughput legitimacy) are not sufficiently decisive to convey state change. Rather, such a focus tends to disguise the asymmetries of power among the members and the minor contribution of Maira Machado is professor of law at São Paulo Law School of Fundação Getulio Vargas. Address correspondence to Maira.machado@fgv.br. The author would like to thank for their comments Bernardo Mota, Pedro Gomes Pereira, Juan Felix Marteau, Guillermo Jorge, Kevin Davis, panels for the Transnational Legal Orders CRN at the Law and Society annual meetings, the participants of the Global Administrative Law Project at workshops at San Andres, Tsinghua, and New York University, and the anonymous reviewers. The author would also like to give a special thanks to Gregory Shaffer. Law & Social Inquiry Volume 37, Issue 2, 330–366, Spring 2012 Law & Social Inquiry Journal of the American Bar Foundation 330 © 2011 American Bar Foundation.