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The Daily Docket — Thursday 5 November: OFAC replaces GL 5Z with GL 5AA, effective 18 December

OFAC issued GL 5AA on 4 November, replacing GL 5Z; the PDVSA 2020 bond authorization now applies from 18 December 2026. Senegal awaits a government decision after the budget rejection.

Sovereign Creditor Review Staff

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Thursday, 5 November 2026 · Coverage to about 00:30 ET, Thursday 5 November · By Sovereign Creditor Review Staff Desks: Venezuela · Cuba & Title III · Senegal · Ethiopia · Other

1. Bottom line

  1. OFAC issued General License 5AA on 4 November, replacing GL 5Z, which had been due to take effect today; the authorization for dealings in the PDVSA 2020 8.5% bond now applies on or after 18 December 2026 (OFAC GL 5AA).
  2. In amended FAQ 595, OFAC said it would encourage parties to apply for a specific license and would have a favorable licensing policy toward an agreement to restructure or refinance payments due to the bondholders (OFAC FAQ 595).
  3. Senegal: no government decision announced after the Assembly's 3 November rejection of the revised budget; no IMF Board date set.

2. Top story: OFAC replaces GL 5Z with GL 5AA

OFAC's GL 5AA authorizes, on or after 18 December 2026, transactions related to, the provision of financing for, and other dealings in the PDVSA 2020 8.5% bond that subsection 1(a)(iii) of E.O. 13835 would otherwise prohibit, and states that GL 5Z, dated 16 September, is replaced and superseded in its entirety effective 4 November (OFAC GL 5AA; OFAC recent actions, 4 November). In the amended FAQ 595, OFAC said that until 18 December no authorization is in effect against that subsection for holders of the bond, so transactions related to the sale or transfer of CITGO shares in connection with the bond are prohibited unless specifically authorized, and that additional licensing requirements may apply to any restructuring or refinancing agreement (OFAC FAQ 595).

El Nacional described GL 5AA as the 28th such extension since 2018 (El Nacional).

Who is affected: Holders of the PDVSA 2020 8.5% bond, CITGO and PDV Holding, and the judgment creditors and bidder in the Delaware sale process for PDV Holding shares. Next trigger: GL 5AA authorization applies from 18 December 2026; Third Circuit ruling on the sale appeals, no date set.

3. What changed

  • 4 Nov · Venezuela (OFAC): GL 5AA issued, superseding GL 5Z; authorization for the PDVSA 2020 bond moves to on or after 18 December 2026 (OFAC).
  • 4 Nov · Venezuela (OFAC): FAQ 595 amended to refer to GL 5AA and to a favorable licensing policy toward a restructuring or refinancing agreement (OFAC FAQ 595).
  • 4 Nov · Senegal: RFI set out the executive's options after the rejection, including amending the bill, decrees for urgent credits, or Article 86 of the Constitution (RFI).

4. Desk notes

Venezuela. See Top story. The Third Circuit has not ruled on the PDV Holding sale appeals (No. 25-3347). The PDVSA Commercial Creditors Committee said in a 3 November press release that it will announce on 17 November an initiative called National Capital to address PDVSA's outstanding commercial claims (PR Newswire). Who is affected: Holders of Republic and PDVSA bonds, PDVSA trade creditors and other external creditors. Next trigger: Committee announcement on 17 November; GL 5AA date of 18 December 2026.

Cuba & Title III. No new Title III ruling or OFAC Cuba action found. London: No new public filing. Next trigger: BICSA wind-down under OFAC FAQ 1276 ends 14 November.

Senegal. No decision announced by the President or government on the next step after the 3 November rejection of Bill No. 40/2026. RFI reported that the constitutional options discussed include amending the text, releasing urgent credits by decree, or adopting the bill under Article 86, which would require the government to engage its responsibility (RFI). SeneNews noted that dissolution of the Assembly is not possible in the first two years of the legislature, installed in December 2024 (SeneNews). Who is affected: Eurobond holders and other external private creditors, commercial-bank lenders and official bilateral creditors; the IMF's USD 2.2bn ECF still awaits Board approval. Next trigger: Government response and IMF Board date, no date set.

Ethiopia. No material change since 22 October 2026; the consent solicitation for the USD 1bn 6.625% Eurobond has not been launched.

Other. Argentina: no new filing in No. 26-442 since the 2 November amicus briefs; responses due 2 December 2026 (Supreme Court docket).

5. Sanctions and markets

  • OFAC (US): 4 November: Venezuela GL 5AA and amended FAQ 595, alongside Iran-related designations and an Iran-related alert; no Cuba action (OFAC).
  • UK: UK Sanctions List last updated 3 November; no Venezuela or Cuba change (GOV.UK).
  • EU: No new Council notice on Venezuela or Cuba found.
  • Markets: No new sourced price reported since the Senegal 2031 bond quote in our 4 November issue.

Disclosure: the proprietor of Sovereign Creditor Review and its affiliates may hold or take positions in matters discussed, and the founders have advised sovereigns and creditors and may do so again. Information only; not legal, investment or other advice. Full disclosure. Corrections: corrections@sovereigncreditorreview.com

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Disclosure: The proprietor of Sovereign Creditor Review and its affiliates may hold, or may take, long or short positions in the debt, claims, securities or litigation interests of any sovereign, issuer or matter discussed on this site. The founders have advised sovereigns and creditors in the past and may do so in the future. Content is for information only and is not legal, investment or other advice.