COMPLAINT → ARCHIVE → APPEAL → NEW COMPLAINT → ARCHIVE → APPEAL
ICAM / CCACM 2026: what was alleged, what was archived, and what actually remains open.
This page does not present bar complaints as proof of misconduct. It reconstructs the procedural sequence and separates what ICAM decided from what it did not decide.
Documentary sequence
| Date | Step | Core issue | Result / status | What was not decided |
|---|---|---|---|---|
| 27 Feb 2026 | First ICAM complaint; Preliminary 434/26 | Íñigo de Luisa and Juan Antonio Ruiz García. Promissory notes delivered in a professional context, client/debtor coherence, continued enforcement, the 23 June 2025 MASC communication, diligence, loyalty and accuracy. | Filed | The complaint did not ask ICAM to retry the debt or court rulings. |
| 6 Mar 2026 | ICAM archive 434/26 · RS-003493/26 | ICAM treated the 2019 cambiario as the starting point and held any potential disciplinary infringement time-barred. | Archived on limitation | ICAM did not decide the professional-conduct merits. |
| 6 Mar 2026 | First administrative appeal | Challenges reduction of the matter to an act exhausted in 2019; points to later professional acts including the 23 June 2025 communication and asks for preliminary fact-finding before fixing limitation conclusively. | Appealed | The appeal seeks investigation, not automatic sanction. |
| 4 Jun 2026 | CCACM procedural order | After receiving ICAM's record on 9 April, CCACM registered and opened the appeal as file 193/2026 and gave the interested lawyers an opportunity to respond. | CCACM 193/2026 pending | This is not a final decision. |
| Jun 2026 | Further submissions and adversarial material | File 193/2026 received later-fact supplements and respondents' submissions. | Record expanded | Cross-submissions are not a merits ruling. |
| 28/29 Jun 2026 | Autonomous ICAM complaint 1487/26 | Cuatrecasas Legal, Íñigo de Luisa, Juan Antonio Ruiz and Teresa Morenés. Reframes the issue around voluntary 2024–2026 acts in ETJ 163/2020 in La Laguna, the advice-to-recovery transition, conflict, secrecy, diligence, good faith and internal controls. | New autonomous route | It expressly does not ask ICAM to decide the debt, promissory notes, adjudication, civil liability or criminal liability. |
| 1 Jul 2026 | ICAM archive 1487/26 · RS-009656/26 | Three separate gates: the 2021 WhatsApp point was held time-barred; the 6 March 2026 LinkedIn message was treated as private/non-professional; and the ETJ acts were treated as territorially within Tenerife rather than Madrid. | Archived + sent to Tenerife | ICAM did not decide that the 2024–2026 ETJ conduct was ethically proper; it held that ICAM lacked territorial competence to decide it. |
| 6 Jul 2026 | Second appeal against archive 1487/26 | Challenges atomisation; treats older facts as context for new acts; seeks preliminary information, preservation, and partial territorial referral without eliminating Madrid-facing modules. | Filed; forwarding trace unresolved | No separate CCACM case number for this second appeal has yet been located. |
Date-control note: the first complaint bears a 27 February filing/date stamp, while the 434/26 archive refers to 2 March as the presentation date. The discrepancy is preserved without interpretation.
How the professional-conduct theory matured
| First complaint | Second autonomous complaint |
|---|---|
| Compact and centred on the use of promissory notes delivered in a professional/fiduciary setting, selection of Matkator as the enforced party, continuing effects of enforcement and consistency with the contractual relationship known to the firm. | More tightly delimited. 2018–2021 material is primarily knowledge/context; the potentially current disciplinary object moves to affirmative, date-specific acts in 2024, 2025 and 2026 and the internal chain that authorised them. |
| The appeal answer was primarily temporal: the conduct could not simply be reduced to 2019 without examination. | The answer to the second archive is twofold: avoid atomisation and, if part belongs territorially to Tenerife, refer that part without materially closing any Madrid or professional-firm modules that remain for Madrid bodies. |
Procedural evolution: limitation → later acts → preliminary information → territorial competence.
The most important contribution of complaint 1487/26
The second complaint separates client · instructor · service beneficiary · invoiced entity · expected payer · promissory-note issuer · judicial debtor. That prevents formal existence of a promissory note from automatically answering the distinct professional-conduct question.
It also frames, as a hypothesis rather than a proven fact, a “progressive inversion of the professional mandate”: adviser with strategic knowledge of the perimeter → own-account recovery → current enforcement/adjudication/possible assignment steps against Matkator. The requested evidence sits largely inside the firm's own records: engagement files, billing, cause of the notes, conflict barriers, DMS access, recovery approvals and the ETJ decision chain.
Limit: the reviewed documents do not prove actual misuse of confidential information, coordination with CAM/HNT/MYND/RIC/Acosta Matos, existence of a connected assignee, or that Matkator could never have been a debtor in any sense.
The immediate procedural traceability gap
The 6 July appeal against archive 1487/26 was submitted through ICAM's portal, but the system registered it as a new complaint under file 1566/26. The same day, written correction was requested so filing RE-007622/26 would be treated as the appeal in 1487/26 and forwarded to CCACM while preserving the filing date.
The present scan has not located a later ICAM confirmation or a CCACM procedural order assigning a number to the second appeal.
The accurate status is therefore: appeal filed 6 July; technical registration as 1566/26; correction/forwarding requested; effective CCACM receipt still to be certified.
What remains open
| Question | Status | Next proof |
|---|---|---|
| Were the merits of the first matter decided? | No. ICAM archived 434/26 on limitation. | Final CCACM decision in 193/2026. |
| Did CCACM formally open the first appeal? | Yes. 4 June 2026 order; file 193/2026. | Monitor proposed/final decision. |
| Did ICAM decide the merits of the 2024–2026 ETJ conduct? | No. It held territorial competence lay in Tenerife and sent 1487/26 there. | Confirm Tenerife receipt and local file number. |
| Has CCACM formally opened the second appeal? | Not shown by the located record. | ICAM forwarding certificate plus CCACM receipt/order and file number. |
| Is an assignee/final remate beneficiary identified? | Not proved in these files. | Complete ETJ and, where appropriate, non-privileged professional/KYC records. |
Publication rule
This page publishes only the procedural architecture and the distinction between allegation, archive, competence and appeal. Confidential annexes, lawyer-client communications and material potentially subject to legal professional privilege are not reproduced.