Jim Barratt
Managing Director

Former SEC Enforcement; Anti-Corruption Compliance & Investigations

Jim Barratt is a Managing Director at Ankura focused on investigations and accounting advisory based in Washington, DC. An experienced forensic accountant, he manages compliance and investigative work connected to corporate fraud, anti-bribery and corruption remediation, and United States Department of Justice (DOJ) and United States Securities and Exchange Commission (SEC) proceedings. Over the past 30 years of his professional life, Jim has served as an independent auditor, internal audit director, chief compliance officer, and SEC enforcement accountant.

  • Experience

    He has performed anti-bribery and corruption compliance reviews and risk assessments for companies in China, Brazil, India, Mexico, Korea, Japan, Singapore, and Europe. Jim has also advised companies and their counsel on profit disgorgement analyses and approaches to government settlements related to Foreign Corrupt Practices Act (FCPA) violations. In addition, Jim has led numerous forensic accounting investigations involving complex accounting issues and financial fraud and assisted counsel in communicating investigation findings to audit committees, SEC staff, and congressional committees.

    Prior to joining Ankura, Jim was an FTI Consulting managing director, a partner with Forensic Risk Alliance, and a managing director in the global forensic and dispute practice of Alvarez & Marsal. He served for six years as an accountant in the enforcement division of the SEC in its Washington, DC, headquarters and more than six years in the audit practice and dispute consulting group of a Big Four firm. Jim was also a deputy director of internal audits for Computer Sciences Corp.

    Jim’s professional experience includes:

    • Assisted companies across a variety of industries in the calculation and evaluation of profit disgorgement in connection with FCPA settlement agreements, providing supportable and reasonable profit disgorgement estimates and presented to the SEC, DOJ, and the Serious Fraud Office.
    • Assisted independent monitors for an oil and gas services company and a global self-service technology company in a review and assessment of anti-bribery and corruption controls, conducting transaction testing and employee interviews and drafted a report of observations. Performed on-site reviews in both India and Mexico.
    • Provided FCPA due diligence services to a global energy company regarding multiple acquisitions of target companies, conducting compliance and anti-bribery/corruption reviews including testing of transactions and employee interviews.
    • Conducted an anti-bribery/corruption review of a Canadian energy company’s China operations, as well as an audit of several of the company’s Chinese third-party distributors.
    • Assisted the independent monitor of a global high-tech manufacturing company in the review and assessment of the compliance function as part of an FCPA deferred prosecution agreement.
    • Coordinated and supervised a multiyear, large-scale forensic accounting analysis and assisted internal and external counsel in the development of litigation claims on behalf of the Lehman Brothers Holdings Inc. bankruptcy estate. Investigated and tracked the movement of billions of dollars of collateral between counterparties and clearing banks in the period leading up to and through the bankruptcy filing. Interfaced with the legal and financial advisors of the unsecured creditors committee, the Securities Investor Protection Corp., the Lehman Brothers’ broker/dealer, the court-appointed examiner, and several large clearing banks.
    • Developed a corporate compliance function while serving as the interim chief compliance officer of a $600 million global manufacturing company facing a DOJ FCPA investigation. Developed corporate compliance policies and conducted training on compliance and FCPA issues to over 400 employees in more than eight countries, including China, India, Korea, and Japan.
    • Assisted outside counsel in an FCPA investigation initiated by whistleblower allegations involving the Latin American subsidiaries of a global pharmaceuticals manufacturer. The work involved interviews of company personnel and securing and reviewing electronic data from the subsidiary in Mexico and Chile.
    • Managed a team of forensic accountants in connection with an internal investigation related to revenue recognition issues at a global electronic components manufacturer. The team worked closely with counsel and the audit committee of the company and held frequent briefings with the outside auditors and the SEC.
    • Led a team in a nine-month internal investigation of accounting and reporting issues at Freddie Mac. The work involved supervising teams of accountants to assist counsel in conducting interviews, reviewing large volumes of electronic and paper records, and researching complex accounting issues. The results of the investigation caused the company to make one of the largest corporate restatements in US history. He made presentations to the board of directors and the SEC and testified before the House Committee on Energy and Commerce.

     

  • News & events
    • Ethics & Compliance Initiative 2017 Annual Conference, 4/26/2017, panel: “ (Not the) Best Practices: Compliance Lessons Learned from Recent FCPA Actions,” Washington, DC, panelist
    • Securities Docket Webcast, 1/18/2017, panel: “Navigating Dodd-Frank’s Whistleblowing Provisions and the FCPA -2016 Update,” Washington, DC
    • Biennial Institute on White Collar Crime, Cleveland Metropolitan Bar Association, 12/9/2016, panel:“Corporate Compliance Programs: Best Practices and Pitfalls to Avoid,” Cleveland, OH
    • Securities Enforcement Forum 2016, 10/13/2016, panel: “FCPA Trends and Developments,” Washington, DC, panel moderator
    • Compliance, Governance & Oversight Council (CGOC) Regional Meeting, 6/15/2016, “FCPA-Analytics for Compliance & Risk Management,” Washington, DC
    • American Bar Association Seventh National Institute on Internal Corporate Investigations and Forum for In-House Counsel, 4/27/2016, panel: “Fundamentals in Corporate Investigations,” Washington, DC
    • Compliance, Governance & Oversight Council (CGOC), 9/16/2015, panel: “FCPA-Proactive Monitoring for Compliance & Risk Management,” Minneapolis, MN
  • In the community