Small investors
The preserved 11 November 2020 webinar presented RICPE as a route for small investors to participate in large Canary projects.
ROLE-02 · PROFESSIONAL DISTRIBUTION / EVENTS
AAFC, RIC Private Equity and the professional RIC-investment channel
This page brings together public and preserved evidence about events aimed at tax advisers, investor marketing that placed Sun Park in the Acosta Matos/RICPE portfolio, and the evidence still required to establish whether client referrals, remuneration or follow-up occurred.
Evidential boundary. Asociación de Asesores Fiscales de Canarias (AAFC) is documented as an organiser/professional-distribution channel for RICPE sessions. The present record does not establish that AAFC recommended Sun Park/MYND Yaiza, acted as an investment intermediary, supplied particular investors, received commissions or knew the final allocation of capital. Those are questions for the records.
1. Documented events
17 June 2021. AAFC published “RIC Private Equity, inversiones RIC con la supervisión del Gobierno de Canarias”, aimed at tax-advice professionals and naming Orlando Luján Mascareño, Enrique Guerra, José Acosta and Luca Mossini among the speakers.
10–11 October 2022. AAFC/Colegio material announced three collective RIC projects, two in Lanzarote. The native event file should identify the projects and materials distributed.
2. The two exact graphics used in preservation routes
These are the same two source-controlled visualisations incorporated in August 2026 into preservation communications sent through professional routes — including PwC, RSM/San Telmo and Grant Thornton — and later through several Ministerio Fiscal / Fiscalía routes. Transmission establishes delivery/custody, not institutional acceptance or a merits finding.
3. RICPE / Acosta Matos investor marketing requiring reconciliation
Sun Park · €12m
José Acosta presented former Aparthotel Sun Park, 220 apartments, four-star transformation and €12m investment.
Third-party RIC investors
The three tourism-renovation projects were said to be in the portfolio so third-party investors could participate by materialising RIC.
Ownership / charges
Statements were made about purchase with own funds, company ownership and absence of mortgage charges. These require testing against title and the later file.
Guarantees / filters
The webinar invoked guarantees, PwC, Uría Menéndez, Intermoney and fiscal/administrative filters. Mention does not establish that each function was performed for Sun Park.
Expected fundraising
Enrique Guerra referred to up to €10m in 2020 and €50–60m the following year across projects: a forecast, not capital actually raised.
4. Material correction: “first investment” must not be converted into Sun Park
CORRECTED. The San Telmo public source records Eduardo Sánchez saying that “the firm” introduced several clients into RICPE's “first investment”. However, RICPE's own public video archive identifies Hotel AC Tenerife as the object of the company's first investment. The San Telmo quote therefore cannot be used as direct proof that those clients funded Sun Park/HNT/MYND. Investor→project allocation evidence is required.
5. Internal 20 July 2021 checkpoint
The signed internal RICPE certification described 262 properties: 54 attributed to CAM, 190 to LPB and 18 to third parties; no signed LOI; comprehensive due diligence not yet begun; and a transaction that could still fail. It is a knowledge checkpoint that must be reconciled against the 2020 investor-facing wording.
This documentary tension justifies production, preservation and reconciliation. It does not by itself establish intent, reliance by a particular investor, public loss or a criminal offence.
6. Recovery plan: what remains and how it closes
The controlled recovery plan is published in full on this page. A relationship remains open until the finite record capable of closing it is produced; accumulated associations are not a substitute for evidence.
AAFC / event
Obtain: native recording, Zoom/chat/Q&A, registrations, decks, project identity, follow-up, referrals, sponsorship/remuneration, deletion policy and custodians.
Closure: native event package + custodian certification + project identification + records-based referral/remuneration answer.
San Telmo / RSM
Obtain: client-introduction, client-origin, conflict, fee, KYC and file-transfer/custody records after integration.
Closure: direct source identifying cohort and project allocation, or certification that allocation was elsewhere/not held.
RICPE / allocation
Obtain: subscriptions, capital calls, project codes, source/referral fields, investment minutes and privacy-safe investor→project matrix.
Closure: dated bridge showing which investors funded which project and under which disclosures.
Gatekeepers
Obtain: actual mandate/work product of PwC, Uría, Intermoney, Cecabank, Luján and other cited controls.
Closure: engagement + work product + information received + limitations + decision chain for each gatekeeper.
Project / operation
Obtain: title, access, HNT, Canarian Hospitality, Meeting Point/FTI, pilots, commercialisation and MYND opening.
Closure: property/right-by-property/right bridge between preparation, authority, funding and operation.
RIC / incentive / FEDER
Obtain: Series F/G, decree/AEAT, GC/836/P06, FEDER and costs by invoice/asset/property/employment.
Closure: reproducible source-and-use matrix showing lawful segregation, overlap or unresolved gaps without presuming double funding.
AAFC questions that must be closed
- Was Sun Park/MYND Yaiza expressly presented, identifiable or discussed in the June 2021 or October 2022 sequences?
- Did AAFC or any organiser refer an adviser, client or investor to RICPE?
- Was any sponsorship, referral remuneration, commission or other benefit provided?
- Were attendees later informed of material changes in title, due diligence, timing or project availability?
Permitted states: DOCUMENTED · SEPARATE-BRIDGE · OPEN · REQUESTED · RECEIVED · NOT-LOCATED · CORRECTED · CONTRARY-EVIDENCE.
7. Right of reply, preservation and limits
AAFC, RICPE, Construcciones Acosta Matos, San Telmo/RSM, PwC, Grant Thornton, co-organisers, named professionals and any materially affected party may provide recordings, records, contracts, invoices, minutes, title documents, reports or corrections. Verifiable corrections will receive equivalent visibility.
Silence ≠ admission. Institutional receipt ≠ merits acceptance. Professional association ≠ automatic transfer of knowledge, intent or responsibility.