On November 14, 2019, Avianca Holdings S.A., an airline holding company based in Panama, disclosed that it continues to investigate potential Foreign Corrupt Practices Act violations initially disclosed in August 2019. In its November 2019 filing, Avianca stated that it had discovered that some company employees, possibly including members of senior management and members of the board of directors, provided things of value to government officials in various countries. Avianca stated that it believed the things of value were limited to free and discounted airline tickets and airline ticket upgrades. Avianca stated that it had voluntarily disclosed its investigation to the US Department of Justice, the US Securities and Exchange Commission, and the Colombian Financial Superintendence in August 2019. The company stated that it is cooperating with the DOJ and SEC investigations.