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The legal environments of organizations facilitate organizational goals by means of a system of procedural rules and vehicles for organizational governance that might otherwise occur through market tactics, espionage, violent self-help, or a range of other mechanisms (Edelman and Suchman 1997, p. 483). In this paper we turn the spotlight on organizational forms operating illicitly: online “hacker” forums that run markets wherein stolen credit card data is bought and sold, and reliance on the legal system of the wider society is not an option for facilitating or regulating transactions (Beckert and Wehinger 2013). The governance structure of these markets for stolen data, in the absence of a reliance on law and state enforcement of contracts, is the main subject of this paper. We develop an analytical framework for the governance structure of online stolen data markets, and we use social network analysis to understand the relational aspects of governance.