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Many of the issue areas that have risen on the international agenda since the end of the Cold War display a common life cycle: an initial, limited agenda centered on an intergovernmental organization, the expansion of that agenda as a result of transnational coalitions of private and NGO actors, growing significance of resources originating with non-state actors, and the development of hybrid forms of governance that incorporate nongovernmental actors, IGOs, and both national and subnational governments. The life cycle of governance complexes associated with climate change, global health, peacebuilding, and “new” trade agreements are variants of this pattern. Global efforts to combat illicit financial flows (IFFs) have also evolved in this fashion, from the modest intergovernmental FATF to a sprawling coalition promoting an agenda to combat IFFs linked to crime, terrorism, corruption, and tax evasion and avoidance. Comparing the anti-IFF governance complex with governance in other issue-areas permits assessment of alternative explanations for the evolution of recently formed governance complexes as well as an evaluation of their legitimacy and effectiveness.