David A. Holley, an executive vice president in the Americas, has more than 25 years of global investigations, business intelligence, corporate governance, and regulatory compliance consulting experience. David draws on his decades of private-sector experience to provide pragmatic advice that integrates his investigative skill set and financial expertise with cutting-edge technology. He excels in the management of high-stakes civil and internal cross-border investigations and is an expert at navigating and mitigating the business and legal challenges posed by doing business in high-risk jurisdictions and industries. He frequently serves as a trusted advisor to a range of clients, including multinational corporations, global law firms, large financial institutions, audit committees, and special committees of boards of directors and their counsel.
David’s investigative and regulatory expertise spans diverse areas including Foreign Corrupt Practices Act (FCPA) and anti-corruption investigations; Office of Foreign Assets Control (OFAC) sanctions compliance investigations and consulting; and Bank Secrecy Act (BSA) and anti-money laundering (AML) investigations. He has extensive experience working with financial institutions, including banks, money service businesses, hedge funds, and investment banks on anti-money laundering initiatives, including reviews of policies and procedures involving Know Your Customer (KYC), Politically Exposed Persons (PEPs), Suspicious Activity Reporting (SAR), and other sanctions regimes. David has also served as a monitor for a major international bank under enforcement supervision.
During his career, David has managed a wide variety of complex corporate investigations and security-related matters, including internal investigations involving fraud, employee, or third-party malfeasance; corporate contests, proxy fights, and hostile takeovers; reputational due diligence matters; intellectual property investigations, patent infringement, and theft of trade secret engagements; corporate governance and integrity monitorship services; and white-collar crime investigations. He has investigated violations of regulatory rules governing auditor independence, the sale and marketing of tax shelters, material misstatements and omissions in filings, self-dealing by corporations and executives, and several other regulatory breaches. These cases have involved contests for corporate control, class actions, short-selling conspiracies, internal wrongdoing, and other securities-related matters.
In addition, David has worked with corporate clients to investigate historic contamination at hazardous waste sites and to build liability cases against potentially responsible parties.
Prior to his role at K2 Integrity, Dave held a senior management position and was part of the global investigations team at Berkeley Research Group (BRG). Before joining BRG, David headed the Boston office of a global consulting and risk mitigation firm and served as an investigator in a prior firm. He also served as a litigation support specialist and investigator with the Environmental Enforcement Section of the U.S. Department of Justice (DOJ). David’s investigative work led to a Certificate of Commendation from the Assistant Attorney General of the DOJ’s Environment and Natural Resources Division.
Dave received his J.D. from the Roger Williams University School of Law and his B.A. from Boston University. He is a member of the International Association of Independent Compliance Monitors, a senior fellow with the Regulatory Compliance Association, and a Certified ISO 37001 Lead Auditor.
Areas of Expertise
- Anti-Bribery and Corruption (ABC) Investigations and Compliance
- Anti-Money Laundering and Combating the Financing of Terrorism (CFT), Sanctions, and Fraud Compliance Programs
- National Security and CFIUS Services
- Corporate Contests
- Enterprise-Wide Financial Crime Risk Assessments
- Financial Investigations and Forensic Accounting
- Fraud Investigations
- Intelligence and Risk Advisory Services
- Internal Investigations
- Litigation Support
- AML Model Validation, System Tuning, and Testing
- Sanctions Risk Advisory Services
- Stimulus and Relief Funding Compliance
- Stimulus and Relief Funding Risk Management
Education and Certifications
- Roger Williams University School of Law, J.D.
- Boston University, B.A.
- Certified ISO 37001 Lead Auditor