Any analysis of the international transplantation of the rules that govern economic activity will generally succumb to the one of two conflicting biases. On the one hand, some see it guided by legalistic reasons: the search for 'better' rules. On the other hand, others argue that dominant economic powers infiltrate and transform weaker systems. Both tend to minimize their differences by suggesting that there is a certain degree of legal and institutional convergence that reflects and reinforces the socio-economic one. The transformation is therefore almost mechanical and can proceed only in one direction.