Avianca Holdings, a Latin American airline holding company, disclosed in a securities filing on Aug. 13 that it is investigating possible violations of the U.S. Foreign Corrupt Practices Act and other anti-bribery laws concerning free and discounted airline tickets and upgrades given to government officials in certain countries.

Through its internal processes, Avianca said it discovered that employees, possibly including members of senior management and members of the board, “provided things of value.” At this time, those things of value appear to be limited to the free and discounted airline tickets and upgrades, the company said.

Avianca said it commenced an internal investigation and retained outside counsel and a forensic investigatory firm to determine whether this practice may have violated the FCPA or other potentially applicable U.S. and non-U.S. anti-corruption laws. Additionally, Avianca said it has “implemented policies designed to prevent such practice from occurring in the future.”

Avianca voluntarily disclosed this investigation to both the U.S. Department of Justice and the Securities and Exchange Commission and is cooperating with both agencies. On the same day, Avianca said it voluntarily disclosed the investigation to the Colombian Financial Superintendence through the National Registry of Securities and Issuers.

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal, enforcement, technology, and more.

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