Source-controlled register · verified to 20 August 2026
What was sent. What came back. What remains.
Twelve stable records consolidate key communications and bounded technical-record references concerning the public bodies and statutory professional corporations shown on the accountability map. Each separates competence, traceable events, evidential limits and one finite outstanding action.
How to read the register
An institutional mark now points to this evidence record—not to an implied relationship.
Registration, receipt, rejection, referral, opening, closure and appeal are different procedural states. A filing proves what was submitted and when; a response proves only what it says. Neither volume nor silence establishes the merits. Public bodies and statutory professional corporations are classified by their distinct competence, not treated as interchangeable.
Competence: criminal investigation, territorial routing and senior prosecution coordination. The three offices below are distinct recipients and procedural records; they are not treated as one file or one decision-maker.
Last verified13 August 2026
Overall statusOne territorial referral; separate closures; coordination questions remain
Arrecife–Lanzarote–Puerto del Rosario
Territorial investigation. On 10 August 2026 the National Court Prosecution Office notified withdrawal in favour of, and referral of GUB 86/2026 to, this Area Prosecutor.
Referral recorded; territorial file number and result not located.
Provincial Prosecutor, Las Palmas
Provincial criminal investigation and review. Decree DI 22/2026 assessed the narrative and documents and closed that file; later submissions were joined to the closure.
Closed record; differentiated new facts require their own route.
Canary Islands Prosecutor · DIP 2/2026
Senior coordination and connected prevaricación allegation. The 2 March check said no appeal was recorded; court records of 28 January and 18 February already documented RPL 3319/2025.
Closure recorded; the documentary appeal-status contradiction is published.
Date
Direction
Reference
Subject / procedural state
10 Aug 2026
National Court Prosecutor → Arrecife Area Prosecutor
GUB 86/2026
Territorial referral; not a merits finding.
2026
Las Palmas Provincial Prosecutor → contributor
DI 22/2026
Closure after assessment; later submissions joined to the closure.
11 Mar 2026
Contributor → Canary Islands Prosecutor
REGAGE26e00026303869 · DIP 2/2026
Formal communication of the already-recorded appeal and requested correction.
ProvesSeparate prosecution offices received, routed or decided identifiable material, and the DIP 2 appeal-status contradiction was formally notified.
Does not proveReferral or registration establishes no offence, guilt, coordination failure, institutional agreement or territorial outcome.
Outstanding finite actionIdentify the Arrecife file and assigned prosecutor; record preservation and a reasoned decision; reconcile DIP 2’s inaccurate appeal premise and keep new extra-insolvency facts separate from closed records.
Competence: judicial governance and discipline within statutory limits; it does not replace appeals or determine civil title, fraud or criminal liability.
Last verified13 August 2026
StatusDI 169/2026 closed; review status to verify
Date
Direction
Reference
Subject / procedural state
2026
Contributor ↔ Registry and Archive Unit
DI 169/2026
Judicial-governance complaint opened and closed; the decision identified review before the Standing Committee within one month.
10 Jul 2026
CGPJ → contributor
DI 169/2026
The closure was maintained.
ProvesAn identifiable disciplinary/governance file was reviewed and closed, with a stated review route.
Does not proveThe closure decides no appeal, title, insolvency merits, fraud, offence or absence of institutional error.
Outstanding finite actionVerify the status of any review and additions; identify conduct, dates and evidence falling within discipline rather than disagreement with rulings.
Competence: supervision of the RICPE vehicle and investor communications, subject to statutory supervisory secrecy.
Last verified13 August 2026
StatusSupervisory action confirmed; outcome not public
Date
Direction
Reference
Subject / procedural state
13 Jan 2021
Contributor → CNMV
RICPE / Sun Park filing
Identified the brochure, webinar, Sun Park, CAM and alleged use of third-party property.
20 Jan 2021
CNMV → contributor
ED/36/2021
Opened a reference and referred the material to the competent department.
22 Jan 2026
CNMV → contributor
Supervisory response
Confirmed supervisory actions and that obtained material lacked the 20–21 July 2021 certificate and court filing.
ProvesNotice, internal routing, supervisory activity and one specific absence from the material obtained.
Does not proveA sanction, endorsement, validation of Sun Park, falsity, criminality or a public merits closure.
Outstanding finite actionPreserve the 2021 and later file and establish internally which representations were tested, by which unit and with what supervisory consequence.
Competence: state-tax control and the tax treatment of RIC materialisation. Tax secrecy and the reporter’s non-party status limit public feedback.
Last verified13 August 2026
StatusNotice established; merits record not located
Date
Direction
Reference
Subject / procedural state
13 Jan 2021
Contributor → AEAT
Tax complaint · “RIC PE investor fraud”
Receipt concerning RIC materialisation and the Sun Park investor narrative.
2025–2026
Contributor → AEAT destinations
12 recorded registrations
RIC alerts and traceability requests; no publication-safe merits decision located.
ProvesThe 13 January 2021 tax notice and later traceable registrations.
Does not provePublic silence is not inaction, acceptance, rejection, a tax offence or a favourable suitability finding.
Outstanding finite actionIndependently test title, beneficiary, cited reports, RIC application and consistency of project versions, and preserve the file and referrals.
Competence: AFCOS coordination concerning operations or projects linked to European Union funds; it is not a general criminal or tax authority.
Last verified13 August 2026
StatusAFCOS file identified; material effect unclear
Date
Direction
Reference
Subject / procedural state
2026
Contributor → AFCOS / SNCA
141-2026-IRR02
File registered concerning the alleged public/EU-funds nexus.
2026
SNCA → contributor
141-2026-IRR02
Located response supplied general channel and scope material.
ProvesAn identifiable AFCOS file and a response about channel and scope.
Does not proveA concrete EU-funds nexus, case investigation, OLAF referral, irregularity or closure on the merits.
Outstanding finite actionIdentify the concrete project and EU fund, if any, and confirm referral, admissibility review, OLAF coordination or reasoned closure.
Competence: distinct functions across Canary taxation, internal control, transparency review, European funds and the Law 2/2023 internal reporting route. These subrecords are grouped for navigation only and are not conflated.
Last verified13 August 2026
Overall statusReferrals, access decisions and pending verification across separate offices
Canary Tax Agency — ATC
Seven registrations are recorded: four received and three rejected as transport states. No publication-safe merits result was located.
Mixed transport traceability; no merits decision.
General Intervention
Responses 184368/2026 and 497011/2026 record consideration within the Integrity Commission and competence-based referrals, including to Justice and Finance/EU Relations.
Referral established; overall control decision unreconciled.
Transparency Commissioner
R2026000054 partially upheld access against Yaiza and required document lists for three municipal files within fifteen working days. A separate 11 August claim challenges Decision 28/2026.
One published partial uphold; other review remains live.
European Funds / Treasury / Law 2/2023
On 12 August the Technical General Secretariat confirmed that REGAGE26e00065752755 was transferred from Treasury to the Directorate-General for Modernisation and Service Quality for Law 2/2023 treatment.
Formal routing established; handler and merits outcome pending.
Date
Direction
Reference
Subject / procedural state
6 Mar / 11 Jun 2026
General Intervention → contributor
Outputs 184368/2026 and 497011/2026
Internal-control scope and referrals; no merits decision on title, aid or funds.
2026
Transparency Commissioner → Yaiza / contributor
R2026000054
Partial uphold; document lists for files 7043/2022, 7059/2022 and 10356/2022 ordered within 15 working days.
15 Jul → 12 Aug 2026
Treasury / Technical Secretariat → Modernisation and Service Quality
Formal routing for Law 2/2023 and Decree 91/2024 treatment.
ProvesSpecific referrals, official responses, a partial access decision and formal Law 2/2023 routing between identified offices.
Does not proveThat ATC, Intervention, the Commissioner, European Funds or the internal reporting system reached the same conclusion—or any merits conclusion.
Outstanding finite actionFor each office, identify the custodian, handler, preserved file, substantive competence exercised, current access status and reasoned outcome; confirm any actual EU-funding line separately.
Competence: municipal planning, works, activity, enforcement and municipal records. Yaiza should identify its documents and checks; it is not asked to determine the lawful tourism operator.
Last verified13 August 2026
StatusPartial access ruling; newer preservation and separate-file requests unanswered on the merits
Date
Direction
Reference
Subject / procedural state
Apr 2022
Municipal technical / police record
1748/2022
Records incomplete documentation and executed works not fully matching material submitted, within the scope described by the file.
2026
Transparency Commissioner → Yaiza
R2026000054
Partly upheld access; ordered document lists for 7043/2022, 7059/2022 and 10356/2022 within 15 working days.
31 Jul–7 Aug 2026
Contributor → Yaiza
Separate-file, preservation and verification communications
Requests separation and preservation of planning, licences, activity, works, tax and declared-title records; no merits response located.
ProvesThe identified municipal files, a binding transparency-access decision and recent traceable requests.
Does not proveThat receipt validates private title, works, licence, compliance, tourism authority, the allegations or any offence.
Outstanding finite actionProvide authenticated indexes and source documents for 7043/2022, 7059/2022, 10356/2022, 1748/2022 and 5854/2022; identify each declarant’s capacity, properties stated and verification performed, or certify a bounded absence.
The public page names files and procedural acts, not private identities, signatures, addresses or raw correspondence. Any remedy date must be calculated from confirmed notice of the relevant act.
08
Cabildo de Lanzarote
Competence: Cabildo-held tourism records, Tourism Planning files and certified extracts within its custody. The operator-history request distinguishes establishment holder, operating undertaking and private-community authority.
Last verified13 August 2026
StatusAccess record established; operator-history allocation and response pending
Date
Direction
Reference
Subject / procedural state
7–9 Apr 2026
Cabildo → contributor
File 614/2026 · Resolution 2026-2735
Granted access and reproduced the 13 March Tourism Planning report identifying 3671/2022, 2984/2023, 17070/2023, 19995/2023, 7206/2024 and 4887/2025.
18 Jun 2026
Contributor → Cabildo
Traceability and preservation communication
Requested author, authority, exact community, units, verification, funding/incentive effects, metadata and specific treatment of Matkator units.
13 Aug 2026
Contributor → Cabildo
REGAGE26e00072883405 · file 614/2026
Requested execution/re-delivery and access to specified records including 3671/2022, 498/2020, 547/2020 and 21219/2021; receipt proves submission only.
ProvesThe Cabildo access decision, the six identified tourism files, formal traceability questions and the 13 August operator-history filing.
Does not proveThat any file validates title, a Community mandate, all-unit authority, a registry change, eligibility or that the latest filing was allocated or accepted.
Outstanding finite actionConfirm allocation and answer REGAGE26e00072883405; provide certified entries, indexes and source acts for H-35/3/0034 / H-35-3-0000034 / LZ/2012/000031, determine whether GE-014212/2014 caused any entry, and state current status/final acts in the six named tourism files.
Ilustre Colegio de Abogados de Las Palmas — ICALPA
Competence: professional-conduct control and preliminary disciplinary handling within its statutory remit. It does not determine private title, civil or insolvency merits, or criminal liability.
Last verified13 August 2026
StatusTwo preliminary files described as open; no later final decision located
Date
Direction
Reference
Subject / procedural state
27 May 2026
ICALPA → complainant
DIP 79/2026
Preliminary information opened concerning the complaint about CAM-side professional presentation; Raúl Galván González was appointed rapporteur.
27 May 2026
ICALPA → complainant
DIP 80/2026
A separate preliminary information file opened concerning insolvency-administrator-side professional handling; Luis Alejandro Guerra Rodríguez was appointed rapporteur.
10 Jun 2026
Complainant → ICALPA
Expansions in DIP 79/2026 and DIP 80/2026
Further claimant submissions in the two files; they are not ICALPA determinations.
ProvesThe reviewed records identify two distinct complaints, preliminary procedural activity and separately appointed rapporteurs.
Does not proveThe truth of either complaint, invalidity of private or court acts, a professional breach, an offence or any final College conclusion.
Outstanding finite actionObtain and verify each complete official file, including service, responses, admitted evidence, current status and any reasoned final determination.
Colegio Oficial de Arquitectos de Gran Canaria — COAGC
Competence: professional registration and conduct within its territorial remit. Custody or issuance of the 2022 visado must be demonstrated; it cannot be inferred from the architect identifier “COAGC 2315”.
Last verified13 August 2026
StatusProject-sheet reference only; no COAGC receipt or decision located
Date
Direction
Reference
Subject / procedural state
25 Feb 2022
Technical record; not a verified COAGC communication
22/000036/7800 · “COAGC 2315”
The reviewed project material states “Partial interior refurbishment and external conditioning of a tourist building”, Sun Park, Yaiza; promoter stated as the Owners’ Community and architect as José D. Acosta Matos. The issuer and custodian are not established by the published source.
ProvesThe reviewed project material contains the stated title, promoter, architect identifier and reference.
Does not proveThat COAGC issued or holds the visado, received a complaint, opened a file or validated title, authority, legality, consent or compliance.
Outstanding finite actionAuthenticate the original visado and issuer; verify the professional-registration reference at the relevant date, identify the dossier, metadata and versions, and locate a receipt before describing COAGC as notified.
“COAGC 2315” is reproduced as a field in the reviewed source. This register does not treat it as proof of the visado issuer, document custody or current professional status.
11
Colegio Oficial de Arquitectos de Lanzarote
Competence: professional-conduct, visado and document-custody functions only to the extent that a record falls within its statutory remit. It does not determine private title, municipal planning compliance or criminal liability.
Last verified13 August 2026
StatusRE 26/008230 registered; allocation, preservation and outcome not located
Date
Direction
Reference
Subject / procedural state
14 Jul 2026
Contributor → College
RE 26/008230
Requested preservation of engagement and authority records, native CAD/BIM plans, metadata, versions, communications and evidence of later use.
ProvesA registered preservation request and the limited documentary scope stated in the reviewed record.
Does not proveAllocation, opening of a professional file, completed preservation, notice to the architect, a breach, the visado issuer, title or planning compliance.
Outstanding finite actionConfirm the handler and file reference, preservation and custodian, any notice and response route, which College holds the visado record, and any reasoned outcome.
Competence: external economic-financial audit of the Canary public sector within its statutory framework. It does not replace tax, judicial, criminal or disciplinary bodies or itself determine civil title or insolvency validity.
Last verified20 August 2026
StatusEntry 1619/2026 established; treatment and substantive response pending
Date
Direction
Reference
Subject / procedural state
19 Aug 2026
Audiencia → contributor
File 145/2026 · outgoing 954/2026
Certificate of the decision concerning file 60/2026 and formal transmission. It records the decision not to initiate an audit, not a merits determination of the underlying facts.
19 Aug 2026, 20:48 → 20 Aug, 08:30
Contributor → Audiencia
REGAGE26e00074022302 · entry 1619/2026
Request for access, clarification, competence delimitation and limited reconsideration. The Audiencia confirmed internal SIR entry; procedural treatment and any decision remain pending.
ProvesThe Audiencia received and internally entered the 19 August follow-up under 1619/2026, documentarily linked to files 60/2026 and 145/2026.
Does not proveAdmission, reopening of an audit, a successful reconsideration, acceptance of allegations or a merits decision.
Outstanding finite actionObtain both file indexes, the Autonomous Community Area report, the inventory of material examined, the competence partition, referrals and a reasoned response to the registered submission.
The native receipt contains personal contact data and a document-verification credential and is not published without redaction. The public record preserves the reference, procedural state and evidential limit.
Historical Portfolio board notice — December 2024 and January 2025
Eight separately registered events distinguish sent emails, a user-supplied messaging account and the native institutional reply. Martin Paul Graham’s historical directorship is established separately from the communications; his departure is registered in July 2025. No whole-board knowledge or completed investigation is inferred.
BORME 460085 · 20 October 2022: director appointment registered 11 October 2022. BORME 357323 · 6 August 2025: cessation registered 30 July 2025. Registration and publication dates are distinct; the underlying corporate resolutions’ effective dates have not been recovered here. Neither notice establishes chairmanship or current office.
Reference correction: the earlier Orion reader labelled these 2024–2025 emails with event numbers 0159–0165, which the canonical register already assigns to other, earlier events. Those canonical events are preserved. The Orion references now use 0191–0198, with 0196 reserved for the separately supplied 11 December account. This is a correction of reader references, not an alias or renumbering of existing canonical events.
2024-12-07 · 23:04:19 UTC · PD-SP-EVT-0191
OUTBOUND_COMMUNICATION · Gil Marer sent an Orion disclosure complaint to Portfolio customer-service and contact functions, requesting a compliance review.
The actual recipient headers establish the Portfolio sends only. The body label naming CNMV as copied does not establish transmission to CNMV. Sending does not prove the allegations or a breach.
OUTBOUND_COMMUNICATION · A separate forward of the Orion complaint was sent to the CNMV information-service route.
This is one of three separately timed sends on this date. Sending does not establish receipt, registration, internal routing, examination or acceptance of allegations.
OUTBOUND_COMMUNICATION · A distinct forward of the Orion complaint was sent to the CNMV complaints-service route.
The transmission is separate from the information-service and whistleblowing forwards. It does not establish destination receipt, a new merits decision or statutory-protection status.
OUTBOUND_COMMUNICATION · Gil forwarded the Orion/CNMV complaint chain to Martin Graham and requested confirmation of safe receipt. Independent BORME records identify Martin Paul Graham as a Portfolio operator director during December 2024.
The email establishes individual escalation. The directorship is independently sourced, not inferred from an address. Sending alone does not prove reading or full-board circulation. The separately supplied 11 December account is a different source.
ATTRIBUTED_INDIVIDUAL_ACKNOWLEDGEMENT · Gil supplied a transcription of a messaging exchange in which Martin Graham reportedly forwarded text attributed to the Legal and Compliance head, acknowledged awareness of the issues, and said an email response would follow.
This is a user-supplied transcription, not an acquired native messaging export. Its displayed times have no established timezone. It is not treated as the same text or timestamp as the native 12 December email. It does not prove the allegations, completed investigation, CNMV contact or full-board knowledge.
INSTITUTIONAL_ACKNOWLEDGEMENT · The native institutional reply, signed by Jaime García-Cruz Carbó, confirms receipt and logging, states intended review and contact with CNMV or other relevant authorities, and provides for preservation and a response on whether assessment is ongoing or concluded.
Acknowledgement and stated process do not prove that CNMV was contacted, an investigation was completed, the allegations were accepted or all directors received the material. The native timestamp is 12 December UTC; it is separate from the supplied 11 December messaging account.
OUTBOUND_COMMUNICATION · Gil sent a renewed Orion escalation to Portfolio compliance, two CNMV functions and Martin Graham. It advances the sender’s further allegations and demands and quotes the December institutional reply.
Actual recipient headers, rather than body-only copy labels, control the transmission claim. The sender’s allegations and requested deadline are not findings or a statutory deadline. Receipt by every recipient and circulation to the full board remain unproved.
PD-SP-SRC-0004 · 2024-12-07 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0191
PD-SP-SRC-0005 · 2024-12-09 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0192
PD-SP-SRC-0006 · 2024-12-09 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0193
PD-SP-SRC-0007 · 2024-12-09 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0194
PD-SP-SRC-0008 · 2024-12-10 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0195
PD-SP-SRC-0009 · 2024-12-12 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0197
PD-SP-SRC-0010 · 2025-01-17 · Authenticated email headers and body reviewed; minimised public derivative, without private addresses or raw correspondence. PD-SP-EVT-0198
24–25 October 2026 · Madrid / CTBG: six separate registration events
The three Madrid entries of 24 October form one documentary delivery family, followed by a supplement on 25 October. The two CTBG submissions maintain the independent access claim. This addition does not revalidate every earlier record. All presentation and registration times below are literal electronic-headquarters times; no timezone offset or later handling is inferred.
PD-SP-EVT-0600
REGAGE26e00091776746
Initial Madrid criminal complaint registration, first part of one three-entry documentary delivery family.
Destination / DIR3: Fiscalía Provincial de Madrid · J00001430
Source and custody: Receipt read copy in the preserved 131-page compilation · Source pages 2-3. No fresh attachment-fingerprint comparison is asserted for this event. The public source-control description identifies provenance; protected native files and unnecessary personal data remain private. A compilation control fingerprint is not a native-receipt fingerprint.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
Source and custody: Receipt read copy in the preserved 131-page compilation · Source pages 4-4. No fresh attachment-fingerprint comparison is asserted for this event. The public source-control description identifies provenance; protected native files and unnecessary personal data remain private. A compilation control fingerprint is not a native-receipt fingerprint.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
Source and custody: Receipt read copy in the preserved 131-page compilation · Source pages 5-5. No fresh attachment-fingerprint comparison is asserted for this event. The public source-control description identifies provenance; protected native files and unnecessary personal data remain private. A compilation control fingerprint is not a native-receipt fingerprint.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
CTBG hearing response maintaining reclamation 3929/2026 and NO DESISTO, accompanied by the Madrid complaint copy and registry receipts. The copy-identity description is qualified by the later 25 October supplement.
Destination / DIR3: Autoridad Administrativa Independiente Consejo de Transparencia y Buen Gobierno · EA0040111
Source and custody: Preserved native registry receipt · Source pages 1-2. No fresh attachment-fingerprint comparison is asserted for this event. The public source-control description identifies provenance; the native receipt and unnecessary personal data remain private.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
Documentary supplement and precisions to the existing Madrid complaint, with a four-page pleading and a 131-page annex containing 15 complete documents; both attachment fingerprints match retained submitted files. The party maintains source-supported allegations while disclosing corrections and contrary evidence.
Destination / DIR3: Fiscalía Provincial de Madrid · J00001430
Source and custody: Preserved native registry receipt · Source pages 1-2. The listed attachment SHA-512 fingerprints were freshly compared and match the retained filed binaries. The public source-control description identifies provenance; the native receipt and unnecessary personal data remain private.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
Supplementary CTBG hearing response and later-obtained documentary material. All four listed attachment fingerprints match the retained submitted files, including the common 131-page annex and Madrid supplement receipt. The submission maintains NO DESISTO and the independent access procedure.
Destination / DIR3: Autoridad Administrativa Independiente Consejo de Transparencia y Buen Gobierno · EA0040111
Source and custody: Preserved native registry receipt · Source pages 1-2. The listed attachment SHA-512 fingerprints were freshly compared and match the retained filed binaries. Its 131-page annex is the common Madrid compilation, not independent corroboration. The public source-control description identifies provenance; the native receipt and unnecessary personal data remain private.
Evidential limit: Registration establishes the recorded presentation and attachment inventory only. The merits and subsequent institutional treatment require separate sources.
