Andrew D. Irwin is a Partner in the Washington office of Steptoe & Johnson LLP, where he is a member of the International and Litigation Departments. He practices at the intersection of international regulatory law and government procurement, focusing 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 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.
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 regarding potential sanctions violations. In addition, he has helped clients address a wide-range of issues related to working in Iraq.
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. In addition, he has conducted FCPA due diligence and audits of sales agents, as well as prepared corporate policies and training materials regarding FCPA compliance. He frequently draws upon his background in public procurement in such matters.
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.
Mr. Irwin is on the Advisory Board for West’s Government Contractor and was a frequent contributor to International Government Contractor. He has spoken at the Government Contracts Year in Review Conference, usually on the FCPA, since the 2007 conference. He is a co-editor, with Ed Krauland, Jack Hayes and Meredith Rathbone, of Thomson Reuters's West International Traffic in Arms Regulations Handbook.
Mr. Irwin received his undergraduate degree from Princeton and his law degree from The GeorgeWashington University. He has also studied at The University of Edinburgh.
Robert D. (Bob) Vander Lugt is the Director of Export Compliance, Northrop Grumman Corporation. As a part of the Northrop Grumman Export Import Shared Service (“EISS”) management team, Mr. Vander Lugt is responsible for export compliance and training matters. He and his staff work with the operating sectors of the company to: craft, implement and maintain export compliance policies and procedures which are maximally effective across the range of the company’s regulated activities, including platform integration, system and subsystem manufacturing, and the provision of defense services; promote standardization and best practice sharing across the enterprise; ensure adequate training of employees; and otherwise manage export compliance risks. Prior to taking his current position at Northrop Grumman, Mr. Vander Lugt served as the empowered official for shipbuilding and night vision businesses within the corporation.
Prior to joining Northrop Grumman in 2003, Mr. Vander Lugt practiced national security law in Washington, D.C., where he represented many of the major U.S. and European defense contractors in export control/technology transfer and sanctions compliance investigations, False Claims Act cases, bid protests, claims, suspension and debarment proceedings, merger and acquisition reviews, and security clearance cases.
Mr. Vander Lugt is Commander in United States Navy Reserve, and presently serves as the Executive Officer of NR JIOCSOUTH 0270, providing intelligence support to SOUTHCOM. He has served on the intelligence staff of the IFOR Commander during U.S. operations in the Balkans, the Staff of the Commander, Navy Reserve Intelligence Command, and on the Intelligence Task Force of the ABA’s Standing Committee on Law and National Security.
As an adjunct professor at the Georgetown University Law Center, Mr. Vander Lugt designed and taught a course in the law of international institutions. He is coauthor of International Rules: Approaches from International Law and International Relations, published by Oxford University Press in 1996 and widely used as a graduate-level textbook in the field. He has lectured on international and national security law topics in the U.S. and abroad for the Republic of China Ministry of Finance, the Forum for U.S.-Soviet Dialog, Georgetown University, the University of Virginia, the National Defense University, the National University of the Republic of China, the International Studies Association, the American Society for International Law, Federal Publications, the National Defense Industries Association of the United States, the Defense Manufacturers Association of the United Kingdom, and the Society for International Affairs, and the Space Coast Trade Council.
Mr. Vander Lugt received his undergraduate degree in History and Government from Oral Roberts University, and his law degree from the University of Virginia. He lives with his wife Ruthie and son Joel in Plano, TX, and enjoys reading history & biography, kayaking, cycling, and chasing Joel’s baby jogger around the park.
Jack R. Hayes is Of Counsel in the Washington, D.C. office of Steptoe & Johnson LLP, where he is a member of the International Regulation and Compliance group. Mr. Hayes has considerable expertise in counseling clients about how to implement successful strategies in the context of overlapping international trade regulatory areas, including with respect to export controls, economic sanctions, anti-money laundering, anti-boycott, and foreign corruption compliance.
Mr. Hayes has experience counseling clients in the defense and commercial sectors regarding their compliance with the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). Much of his practice relates to enforcement matters, including voluntary disclosures, internal investigations of apparent export control violations, and assessments of compliance obligations in accordance with relevant international trade requirements. He also has assisted clients in the preparation of legal memoranda interpreting provisions of the ITAR and EAR, license applications, advisory opinion requests, commodity jurisdiction and classification analyses, including with respect to encryption technology, and compliance programs, policies, or manuals. He is a co-editor, with Andy Irwin and Ed Krauland, of Thomson West’s International Traffic in Arms Regulations Handbook.
Mr. Hayes has advised clients in various industries regarding compliance with U.S. and multilateral economic sanctions targeting specific countries, such as Cuba, Iran, Sudan, and Myanmar (Burma), and persons or entities acting contrary to the interests of the United States, including terrorists, proliferators of weapons of mass destruction, and narcotics traffickers. He has assisted clients in the preparation of license and advisory opinion requests for, submission of blocking reports to, resolution of administrative subpoena requests in connection with, and related oral advocacy concerning officials in the U.S. Department of the Treasury and U.S. Department of State. This practice also has involved counseling clients on the intersection of economic sanctions and anti-money laundering/anti-terrorism financing laws and regulations, including the creation of compliance programs, know-your-customer and due diligence best practices, and reporting requirements.
Mr. Hayes has counseled clients on anti-corruption compliance issues, with particular emphasis on the intersection of the Foreign Corrupt Practices Act and Part 130 of the ITAR. He also has prepared multi-jurisdictional corporate policies, compliance manuals, due diligence tools, draft compliance language for international agreements or terms and conditions, and ethical codes of conduct to assist clients with anti-corruption initiatives.
Mr. Hayes earned his B.A. from Furman University and his J.D. from Northwestern University. Prior to law school, Mr. Hayes worked on a number of legal international trade and tax matters involving the jurisdiction of the House Committee on Ways and Means and the Senate Committee on Finance.
Meredith Rathbone is a Partner with the law firm of Steptoe & Johnson LLP in Washington, D.C., where she practices in the International Law Department. Ms. Rathbone focuses her practice on counseling clients regarding international regulations and compliance, including compliance with U.S. export controls and economic sanctions laws.
Ms. Rathbone has advised and assisted clients in undertaking numerous internal investigations in the United States and abroad relating to compliance with the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR) and U.S. sanctions laws. She regularly advises clients on making voluntary disclosures and has interfaced on behalf of clients with Government officials following such disclosures. In addition, Ms. Rathbone is experienced in assisting clients in navigating all other aspects of export controls and sanctions compliance, including the establishment of compliance programs designed to prevent inadvertent violations of the law, undertaking commodity classification and jurisdiction assessments, seeking licenses, obtaining approval for and managing Technical Assistance Agreements (TAAs) and Manufacturing License Agreements (MLAs), and undertaking internal audits. Ms. Rathbone also advises clients on customs, anti-corruption, and international government procurement matters.
Ms. Rathbone writes and speaks regularly on international regulatory compliance matters. She is a Vice Chair of the American Bar Association, Section of International Law’s Export Controls and Economic Sanctions Committee. In addition, she has taught courses relating to international law as an adjunct professor at Georgetown University and Georgetown University Law Center.
Ms. Rathbone earned her undergraduate degree from the Georgetown University School of Foreign Service, and her law degree from Georgetown University Law Center. She has also studied in Finland, Russia, and Italy.