In its Form 6-K filed with the US Securities and Exchange Commission on 23 October 2019, Avianca Holdings S.A., a Latin American airline holding company organized under the laws of Panama, revealed that it had made a voluntary self-disclosure to the Office of Foreign Assets Control of the US Department of the Treasury on September 25, 2019. Avianca indicated that, as a result of a transfer of approximately 78% of the company’s voting shares from a Panama-based company to a Delaware company, Avianca became subject to US jurisdiction for purposes of US sanctions laws. The company identified some regular passenger flights to and from Havana, Cuba that may inadvertently have violated US Cuban Assets Control Regulations. Avianca says that it is cooperating with OFAC regarding these flights, but that it is too early to predict what action, if any, OFAC may take. The company also plans to request that OFAC grant specific authorization for Avianca’s subsidiary airlines to continue to fly to and from Cuba.