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The increasingly popular multi-stakeholder process gives voice to a wider array on non-governmental actors. This paper focuses on the fundamentals of the cybersecurity challenge for commerce. It examines one important effort to build a trusted digital environment that is taking place within The Society for Worldwide Interbank Financial Telecommunication. SWIFT is an unusual multi-stakeholder organization (MSO), a society of international financial institutions that secures financial transfers across borders. The case of SWIFT helps demonstrate what is required for an international governance regime to succeed in a complex, technologically dynamic space. Any regime is more likely to succeed if it addresses threshold challenges for creating a core club, authoritative minimum international baselines, and partial convergence of national policies. Robust regimes increasingly rely on MSOs that are credibly expert, transparent to important stakeholders, and accountable to governments.