Andrew D. Irwin

Of Counsel

1330 Connecticut Avenue, NW
Washington DC 20036
TEL: 202.429.8177
FAX: 202.429.3902

Andrew D. Irwin is of counsel in the Washington office of Steptoe & Johnson LLP, where he is a member of the Litigation and International Departments. He practices at the intersection of government procurement and international regulatory law, focusing primarily on corporate investigations and related compliance counseling. He has a particular background in laws and regulations that relate to government contracting fraud, export controls and sanctions, and foreign corruption, as well as considerable experience in general corporate ethics and compliance counseling, administration and program development. He has conducted investigations in Europe, Asia, and the Middle East (including on the ground in Iraq). Prior to coming to Steptoe, Mr. Irwin spent several years as inside counsel for one of the world’s largest engineering and construction companies.

Government Contracts
Mr. Irwin has counseled clients on topics such as procurement integrity/contracting ethics, foreign acquisition, data rights/proprietary information, schedule contracting, small business subcontracting, the SAFETY Act/P.L. 85-804, and use of non-traditional acquisition vehicles such as “other transactions.”

As inside counsel to a major government and international contractor, Mr. Irwin advised senior management, business development, and procurement personnel regarding a full range of contract formation and administration issues involving numerous significant programs for the US Departments of Defense and Energy, as well as the US Agency for International Development. In addition, Mr. Irwin supervised bid protest litigation and was responsible for a number of Freedom of Information Act-related matters.

Export Controls, Sanctions, FCPA
Mr. Irwin has considerable experience counseling clients in a number of industries regarding their compliance with the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), including developing policies and procedures to prevent and detect violations and preparing license, classification and commodity jurisdiction requests, as well as conducting internal investigations. In addition, he frequently counsels clients on “deemed export” issues. Mr. Irwin has also counseled clients regarding all major US sanctions regimes administered by the Office of Foreign Assets Control (OFAC), and has helped clients address a wide-range of issues related to working in Iraq. He has assisted clients with respect to voluntary disclosure and enforcement matters at the Commerce, State, and Treasury Departments.

Mr. Irwin has extensive FCPA experience. He has conducted Foreign Corrupt Practices Act (FCPA) due diligence, conducted audits of sales agents, prepared corporate policies and training materials regarding FCPA compliance, and investigated potential FCPA violations in numerous locales, including having conducted dozens of witness interviews.

Government Enforcement & Corporate Compliance
Mr. Irwin has litigated a number of False Claims Act cases and related matters, including those brought by qui tam relators. His clients have included defense, healthcare, and petroleum companies. He has prepared the full-scale compliance program required as part of a defense industry settlement. In addition, while in-house, he was actively involved in developing and administering a global ethics and compliance program for a major company. Mr. Irwin has also assisted clients in parallel criminal investigations, including responding to criminal subpoenas, preparing for and reacting to search warrants, and interacting with IG and FBI agents.

Noteworthy

He has been an Associate Professorial Lecturer in Law at the George Washington University Law School, a guest lecturer for its Government Contracts Program, and has given numerous CLE presentations on a wide range of government contracts and international topics for Federal Publications Seminars, including running a course on ITAR compliance and audits. In addition, he was the course director for a program on government contracts and legal ethics. He is also a frequent author on government contracts, export controls/sanctions, and corporate compliance and is on the Advisory Board for Thomson West’s The Government Contractor as well as a frequent contributor to Thomson West’s International Government Contractor . He was a speaker on export controls and FCPA topics at the 2007 Thomson West’s Government Contracts Year in Review Conference. He is a co-editor, with Ed Krauland and Jack Hayes, of Thomson West’s International Traffic in Arms Regulations Handbook.

Select News & Events

Steptoe FCPA Alert Published by Competition Law360
Andy Irwin Quoted in Government Contractor
Sanctions' Impact on Reconstruction
Homeland Security Contracting
Export Control Transformation
Government Contractors Abroad
National Forum on Government Contracting Ethics & Organizational Conflicts of Interests (“OCIs”), September 24, 2008
Managing Regulatory Compliance with both US and EU Export Controls, July 29, 2008
ITAR Compliance and Audits, July 17, 2008
Export Control Compliance for Government Contractors, June 4, 2008
ITAR Compliance and Audits, May 8, 2008
The Last Barriers to Opening the Chinese Procurement Market: Export Controls, Compliance and National Security Concerns, February 26, 2008

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Publications

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