Overview
Carl Hahn is a partner in Steptoe's Investigations, White-Collar Defense and Compliance practice. He advises multinational corporations, boards, and public sector entities on complex compliance, governance, and regulatory matters, with a particular focus on artificial intelligence, data analytics, and emerging technologies. Carl brings more than two decades of senior in-house experience and legal leadership in the defense, aerospace, and technology sectors, including serving as Chief Ethics & Compliance Officer at Northrop Grumman and Vice President & Associate General Counsel at IBM.
Carl co-founded with Matt Galvin, Gentic Global Advisors PLLC, a boutique advisory firm that integrates legal, compliance, and data science experience to help organizations modernize compliance programs, conduct cross-border investigations, and design trustworthy AI governance frameworks. His work spans the deployment of automated anti-corruption due diligence systems, enterprise-wide risk assessments, and the operationalization of AI governance controls aligned with evolving regulatory and legal expectations.
At Northrop Grumman, Carl led the transformation of the company's global compliance function, embedding analytics into operations and serving on the AI Governance Board, Digital Transformation Team, and Operations Council. He oversaw legal teams responsible for export/import controls, sanctions compliance, and FTC-monitored obligations related to solid rocket motor engines. His leadership positioned Northrop as a recognized industry voice in values-based AI governance.
Earlier in his career, Carl held senior legal roles at IBM, including leading global investigations and compliance teams across Europe, the Americas, and Asia. He managed complex litigation, regulatory matters, and internal investigations, and served as Assistant General Counsel in Tokyo, where he engaged with Japanese regulators and oversaw legal operations.
- New York
- District of Columbia
- Virginia
- J.D., University of Virginia School of Law, 1991
- B.A., College of William & Mary, with honors
Representative Matters
- Led Northrop Grumman's compliance response to the FTC's 2018 decision and order regarding solid rocket motor contracts, including oversight of legal obligations and internal controls.
- Designed and deployed enterprise-wide AI governance frameworks at Northrop Grumman, integrating legal, ethical, and operational safeguards for emerging technologies.
- Oversaw global investigations and compliance programs at IBM, including cross-border FCPA and anti-corruption matters across Europe, the Americas, and Asia.
- Served as Assistant General Counsel and Director at IBM Japan, managing complex litigation and regulatory interactions with Japanese authorities.
- Co-founded the Compliance Leadership Roundtable in partnership with UVA, Duke, and Harvard Business School, fostering thought leadership in ethics and compliance.
- Presented on agentic AI governance and compliance innovation at leading forums including NYU, SCCE, Naval War College, and the American Conference Institute.
News & Publications
StepTechToe
Department of Commerce Launches American AI Exports Program
October 30, 2025
By: Evan T. Abrams, Carl Hahn, Michel Paradis, Sophia Breggia
Professional Affiliations
- Trustee, The Washington Center
- Director, Integrity Distributed
- AI Governance Board Champion, Credo AI
