This analysis examines the legal implications of the May 13, 2026, announcement of the restructuring of Venezuela's external debt. There are three central conclusions: (i) the announcement covers all external public debt owed to private creditors, including non-financial debt arising from contractual awards and claims; (ii) under General License 58, the Government may undertake only preparatory actions, or "step zero," without authorization to negotiate directly with creditors; and (iii) these preliminary actions are informed by the general principles of administrative law, including transparency, and will be reinforced by the institutional anchorage of the International Monetary Fund. […]