ASHLEY DALMAU HOLMES is an associate in the Chicago office within Sidley’s White Collar: Government Litigation & Investigations group. She has extensive experience conducting complex domestic and international internal investigations on a variety of matters, including the Foreign Corrupt Practices Act (FCPA), fraud, bribery, and securities regulations. She represents clients before law enforcement and regulatory agencies, including the United States Department of Justice (DOJ), the United States Securities and Exchange Commission (SEC), the Federal Bureau of Investigations (FBI), and other regulators. In addition, Ashley assists clients in the development, implementation and evaluation of corporate compliance policies, protocols, and internal controls and has experience conducting anti-corruption and compliance-related due diligence in the business transaction context.
Ashley also has a wide range of litigation experience, including trial, arbitration hearings, oral arguments, preparing fact and expert witnesses for deposition and trial, managing large-scale electronic discovery and drafting dispositive motions, appellate briefing and other briefs.
Representative engagements include:
- Lead associate on numerous internal investigation/regulatory compliance matters representing Fortune 500 companies with operations in Central and Latin America concerning potential issues arising under federal securities laws and the FCPA.
- Lead associate responsible for developing and implementing comprehensive and targeted compliance assurance and ethics programs, developing merger and acquisition anti-corruption due diligence protocols, and conducing anti-corruption due diligence reviews for numerous Fortune 500 companies.
- Lead associate responsible for drafting numerous dispositive motions seeking enforcement of consumer arbitration clauses to defeat class action lawsuits.
- Representing a major international pharmaceutical company in a federal investigation involving allegations of violations under the False Claims Act and Anti-Kickback Statute based marketing and contracting practices, including allegations of off label promotion and kickbacks.
- Representing a major international pharmaceutical company in qui tam litigation brought in the Southern District of New York by government and relator, alleging kickbacks to specialty pharmacies in connection with various medications.
- Representing a major national Spanish radio station operator in an internal investigation concerning potential issues arising under federal securities laws and the FCPA.
- Representing a major international manufacturer of cosmetics in a cross-border investigation in El Salvador, Mexico, Panama, Guatemala and Nicaragua concerning possible violations of the FCPA.
- Representing clients in non-public government investigations, including before the DOJ, SEC and FBI.
- Representing clients in internal investigations concerning allegations of fraud, insider trading and other wrongdoing.
- Representing multiple companies in responding to third-party discovery requests in subpoenas and Civil Investigative Demands, and assisting clients with narrowing the scope and burden of such requests.
Ashley is also actively engaged in the civic, legal, and professional communities at large. Ashley is a member of the Legal Aid Chicago Ambassadors Board, which supports the mission and programmatic work of Legal Aid Chicago by helping to raise awareness for civil legal services and help obtain the resources needed to make equal justice a reality for the most vulnerable people in our community. In May 2019, Ashley was certified as a Mediator for the Center for Conflict Resolution, which provides free conflict resolution and mediation services in the greater Chicago area.
Ashley graduated cum laude from the University of Notre Dame Law School. She earned her bachelor’s degree at the University of Notre Dame, where she studied Political Science and Greek and Roman Civilizations.