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For Jeanne Archibald, international trade law isn’t just about following the goods. It’s also about following the money. A former general counsel of the Treasury Department, Archibald, 56, is known for her expertise on economic sanctions, export controls, money laundering, trade negotiations, and national security reviews of foreign investment in the United States. For example, the Hogan & Hartson partner recently led the defense of a Latvian bank in a complex money-laundering investigation by Treasury’s Financial Crimes Enforcement Network. In 2005, the department moved to designate JSC Multibanka as a primary money-laundering concern and issued a proposed ruling that would bar U.S. banks from maintaining corresponding accounts with the bank. Archibald says her role was “to develop a strategy and help the bank execute what needed to be done to convince Treasury that [the bank] had dealt with their concerns.” She succeeded when Treasury withdrew all proposed restrictions against Multibanka last year. That’s not the only client she has recently pulled out of a jam. Archibald represented an American company facing “a very serious enforcement action” by the U.S. Department of Agriculture, she says. The company was suspected of violations of the Oil-for-Food program in Iraq; bribes and kickbacks were alleged. She declines to name the client, but with her help, the company persuaded the government to drop the action. One longtime client is Toyota Motor Corp. For the past 14 years, Archibald has advised the company on a wide range of international issues. “She does an excellent job,” says Earl Quist, director of industry affairs for Toyota Motor North America Inc. “She’s a wonderful listener, and she is quickly able to understand what our executives are really interested in knowing about.” Archibald makes an annual trip to Toyota’s corporate headquarters in Japan, where she meets with the chairman, president, and senior executives. “When she makes a recommendation to our executives, they take it very seriously,” says Quist, describing her as “our most trusted eyes and ears about thinking within the U.S. government.” Archibald has also advised foreign governments. For example, she was tapped by the Bahamas to assist in negotiating a tax information exchange agreement with the United States in 2002. Last year, she helped guide through a national security review of the merger between Gemplus International S.A. and Axalto Holding N.V. Gemplus, based in Luxembourg, and Axalto, based in the Netherlands, both have U.S. subsidiaries that make secure cards — the kind that employees swipe to gain access to restricted areas. Because of the high-tech security nexus, the transaction was of interest to the Committee on Foreign Investment in the United States, an interagency group chaired by the treasury secretary. In what are called Exon-Florio reviews, CFIUS evaluates the national security risk of deals involving direct foreign investment in the United States. The tricky part of the Gemplus-Axalto deal, notes Archibald, was the timing. The merger was the first to be reviewed after the 2006 outcry over the Dubai Ports World deal, which would have turned over management of major U.S. seaports to a company based in the United Arab Emirates. “Everyone was very focused on that,” recalls Archibald. But she still got the review completed in time, and Stephen Juge, deputy general counsel of Gemalto (as the merged company is now known), sings her praises. “She is an outstanding, consummate professional who is remarkably knowledgeable in her field,” he says. “Her excellent skills of persuasion permit her to achieve excellent results, exceeding client expectations. She’s cr�me de la cr�me, one of the best lawyers I’ve ever worked with.” Archibald comes by her CFIUS expertise firsthand. As deputy general counsel at the Treasury Department, she was one of the principal department officials working with Congress on the 1998 Exon-Florio amendment to the Defense Production Act of 1950. The law gives the president the power to block or undo any foreign direct investment in the United States if it is deemed a threat to national security. Archibald began her career in government, after earning a J.D. from Georgetown University Law Center in 1977, when she went to work for the House Ways and Means Subcommittee on Trade. In 1980, she became associate general counsel in the Office of the U.S. Trade Representative, where she oversaw proceedings under Section 301 of the Trade Act of 1974. Prior to the establishment of the World Trade Organization, domestic parties turned to Section 301 to seek executive branch support in resolving international trade disputes. By 1986, she says, “I had begun to feel that I had my arms well around the issues. I wanted to round out my knowledge to include the financial flows that accompany trade and goods.” So she moved to Treasury, serving as deputy assistant general counsel for international affairs, deputy general counsel, and, from 1990 until early 1993, general counsel. After those 16 years in government, Archibald joined Hogan & Hartson, where she is now one of six managing partners firmwide. She also heads the 45-person trade team, where notable colleagues include partners Mark McConnell and Lewis Leibowitz and senior international advisers Clayton Yeutter and Hugo Paemen.

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