- 2121 Avenue of the Stars
- Suite 2800
- Los Angeles, CA 90067
- TEL: +1 310 734 1926
- FAX: +1 310 734 1927
Areas of Practice
- Economic Sanctions
- Export Controls
- Government Contracts
- Industrial Security
- International Regulation & Compliance
- The George Washington University School of Law, J.D., with honors, 1996
- Princeton University, A.B., magna cum laude, 1993
Bar & Court Admissions
- District of Columbia
Andrew D. Irwin
Washington DC 20036
TEL: +1 202 429 8177
FAX: +1 202 429 3902
Andrew D. Irwin is a partner in Steptoe’s Washington and Century City offices, and focuses his practice at the intersection of international regulatory law and government procurement, concentrating primarily on corporate investigations and related compliance counseling. He has a particular background in laws and regulations that relate to export controls/sanctions, foreign corruption, and government contracting fraud. He also has considerable experience in general corporate ethics/compliance counseling, as well as ethics/compliance program administration and development. He has conducted investigations and reviews in Europe, Asia, Africa, and the Middle East (including on the ground in wartime 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.
Mr. Irwin has considerable experience counseling clients in a number of industries regarding their compliance with the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR). Much of his practice relates to enforcement matters, including voluntary disclosures and related internal investigations. He also advises clients regarding developing policies and procedures to prevent and detect violations and preparing license, classification and commodity jurisdiction requests. Mr. Irwin has also counseled clients regarding all major US sanctions regimes administered by the Office of Foreign Assets Control (OFAC) and conducted investigations and prepared voluntary disclosures regarding potential sanctions violations. In addition, he has helped clients address a wide-range of issues related to working in contingency contracting environments such as Iraq and addressing supply chain compliance risks when supporting US government contracts abroad. He has also acted as a regulatory counsel in M&A transactions.
Mr. Irwin also has extensive Foreign Corrupt Practices Act (FCPA) experience. He has investigated potential FCPA violations in numerous locales, including having conducted dozens of witness interviews and advised clients who face enforcement action from the Department of Justice and the Securities and Exchange Commission. In addition, he has conducted FCPA/anti-corruption due diligence relating to M&A transactions and conducted and supervised audits and reviews of sales agents and other business partners or third parties. He has also prepared corporate policies and training materials regarding FCPA compliance, as well as advised clients regarding overlapping third country and local law risks. He frequently draws upon his background in public procurement in such matters, including advising clients regarding suspension and debarment risks. He also has experience with respect to anti-corruption issues involving the World Bank. To watch a video of Mr. Irwin speaking about the FCPA, click here.
Mr. Irwin has counseled clients on a wide range of government contracts issues. A particular area of focus is ethics and compliance, including issues associated with gratuities, bribery, kickbacks and government hiring. Other topics on which Mr. Irwin has provided advice include contingency contracting, foreign acquisition, teaming, proprietary information, schedule contracting, small business subcontracting, and P.L. 85-804. He also assists clients with transactional due diligence.
In addition, 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.
Government Enforcement & Corporate Compliance
Apart from Mr. Irwin’s experience in international enforcement areas such as the FCPA and export controls, Mr. Irwin has also 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.
- Mr. Irwin 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 international and government contracts topics for Federal Publications Seminars. His CLE presentations have included developing and teaching a course on ITAR compliance and voluntary disclosures as well as a course on the fundamentals of government contracts. He also has developed, and co-teaches, Federal Publications’ live course regarding the FCPA. He is also a frequent author on government contracts, international regulatory matters such as export controls/FCPA, and corporate compliance. In 2011 he hosted, with Lucinda Low, a multi-part series of video tutorials for Thomson Reuters on global corruption issues.
- He is on the Advisory Board for Thomson Reuters/West’s The Government Contractor and was a frequent contributor to Thomson Reuters/West’s International Government Contractor. He was a speaker on export controls and FCPA topics at the 2007 Thomson Reuters/West’s Government Contracts Year in Review Conference, spoke at the 2008-2012 Year in Review Conferences primarily on the FCPA and US sanctions and will participate in the 2013 conference. He also spoke at Thomson Reuter’s Western Briefing Conference from 2010-2012, primarily regarding the FCPA and is scheduled to speak in 2013 regarding FCPA and ITAR developments relating to government contractors. He is a co-editor of Thomson Reuters/West’s International Traffic in Arms Regulations Handbook and also co-editor of Thomson Reuters/West’s Economic Sanctions Desk Reference. He is also a regular speaker at events for the American Conference Institute, Momentum Events, and the National Contract Management Association, including having been one of the plenary panel speakers at NCMA’s 2013 World Congress.
- He is the Co-Chair of the International Procurement Committee of the ABA Section of Public Contract Law and moderated a panel on international procurement at the 2011 ABA Annual Meeting in Toronto and is scheduled to moderate a practicum on Foreign Military Sales at the ABA Section of Public Contract Law’s Fall Meeting in 2013. He has moderated several other ABA-sponsored panels on anti-corruption issues, including the UK Bribery Act. He was a core-team member of the ABA’s Services Contracting Best Practices Task Force and contributed to its published report. He has also participated in several ABA public comment efforts regarding export control issues.
Select News & Events
- Export Controls, Compliance and National Security Concerns, Thomson Reuters/West Government Contracts Year in Review Conference, February 18, 2014
- Export Controls, FCPA and International Regulatory Compliance, 2013 Government Contracts Review & Outlook, Thomson Reuters Federal Publications Seminars, December 5, 2013
- International Traffic in Arms Regulation Course, Thomson Reuters Federal Publications Seminars, October 23, 2013
- Foreign Corrupt Practices Act Course, Thomson Reuters Federal Publications Seminars, October 21, 2013
- Addressing the US/UK Exemption, Momentum ITAR Summit, June 24, 2013
- Export Controls, Compliance and National Security Concerns, Government Contracts Year in Review Conference, February 19, 2013
- Steptoe Announces Promotion of 13 Lawyers
- Law360 Quotes Andy Irwin’s Tips for Foreign Cos. to Win US Government Contracts
- “Export Controls, Compliance and National Security Concerns” at the Government Contracts Year in Review Conference in Washington, DC
- Constructing, Implementing, and Managing Effective Ethics Compliance Programs
- Steptoe FCPA Alert Published by Competition Law360
- Andy Irwin Quoted in Government Contractor