Sungjoon Cho is a Professor of Law, Chicago-Kent College of Law. Jacob Radecki is an Associate at Levin & Perconti. Cecilia Suh is an Associate at Funkhouser Vegosen Liebman & Dunn. We thank Claire Kelly, Kenneth Abbott, Duncan Snidal, David Levi-Faur, Timothy Lytton, Joel Trachtman and participants of SASE Regulatory Intermediaries Workshop in London and the WTO 20 Conference at Harvard Law School for their helpful feedback. Kathleen Mallon provided excellent research assistance.