After leaving the Judiciary, Holmes became the Vice Chairman, Legal, Risk and Regulatory, and Chief Legal Officer for global accounting firm KPMG. At KPMG, he directed the office of general counsel, risk management, government affairs, security, and ethics and compliance programs. He was also counsel to the board of directors and a member of the management committee. In 2009, "Ethicsphere" named him one of America's 100 most influential people in business ethics. In 2007, "Accounting Today" named him one of the "Top 100 Most Influential People in Accounting." In 2014, National Law Journal named him "America's 50 Outstanding General Counsel." In 2018, Holmes received the "Scales of Justice Award" from Equal Justice Works, a "nonprofit organization that brings together an extensive network of law students, lawyers, legal services organizations, and supporters to promote a lifelong commitment to public service and equal justice."