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Alexandra Barbee-Garrett

Counsel | She/Her/Hers

Overview

Alexandra Barbee-Garrett is a counsel in Crowell & Moring’s Washington, D.C. office, where she practices in the Government Contracts Group.

Alex helps companies navigate the complex requirements around doing business with the U.S. government, with a particular focus on government contracts and grants compliance issues, government ethics, and lobbying laws. Her practice spans a broad range of counseling, investigatory, and litigation matters, including: compliance reviews and enhancing contractor compliance programs; representing clients in suspension and debarment proceedings; counseling on supply chain security and sourcing issues; voluntary and mandatory disclosures; internal investigations related to the False Claims Act, the Procurement Integrity Act, and other civil and criminal matters; and bid protest and claim litigation. Alex also helps clients understand developing legislative requirements in the supply chain and government contracting spaces.

Prior to joining Crowell & Moring, Alex was a law clerk to Judge Richard A. Hertling of the U.S. Court of Federal Claims. Before law school, Alex worked as a health care legislative assistant for Rep. Rick Larsen (WA) in the U.S. House of Representatives.

Career & Education

    • U.S. Court of Federal Claims
      Law Clerk, Judge Hertling, 20192020
    • United States House of Representatives
      Legislative Assistant, 2011–2013
    • U.S. Court of Federal Claims
      Law Clerk, Judge Hertling, 20192020
    • United States House of Representatives
      Legislative Assistant, 2011–2013
    • The George Washington University Law School, J.D., with honors, 2016
    • University of Washington, B.A., 2010
    • The George Washington University Law School, J.D., with honors, 2016
    • University of Washington, B.A., 2010
    • District of Columbia
    • Virginia
    • U.S. Court of Federal Claims
    • U.S. Court of Appeals for the Federal Circuit
    • District of Columbia
    • Virginia
    • U.S. Court of Federal Claims
    • U.S. Court of Appeals for the Federal Circuit

Alexandra's Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert....

Alexandra's Insights

Client Alert | 2 min read | 05.14.26

Proposed DFARS Rule Could Require Disclosures and Mitigation Related to Foreign Ownership, Control, and Influence (FOCI) on Certain Unclassified Contracts

On May 7, 2026, the Department of War issued the long-awaited Proposed Rule to implement Section 847 of the FY 2020 National Defense Authorization Act (NDAA) regarding Foreign Ownership, Control or Influence (FOCI) requirements for contractors. The proposed rule would expand the applicability of FOCI reviews, requiring contractors and subcontractors on unclassified “covered contracts” — defense contracts and subcontracts valued in excess of $5 million that are not for commercial products and services — to submit FOCI disclosures to the Defense Counterintelligence and Security Agency (DCSA) for FOCI risk assessment (and as applicable, mitigation) as part of contract award. This would effectively require DCSA assessment and adjudication of FOCI considerations prior to contract award. Thus, both cleared and uncleared defense contractors would be subject to the rigorous DCSA disclosure requirements, scrutiny, and FOCI mitigation. Crowell discussed the Section 847 requirements in a prior alert....