OPEN FILE · DOCUMENTS BEFORE CONCLUSIONS
This gateway does not ask CNMV to adopt Project Sun Rock’s global theory or determine civil title, insolvency, grant compliance or criminal responsibility. It provides a bounded review of information, governance, conflicts, due diligence, re-entry, funding, preservation and any correction within the RICPE perimeter.
We invite the competent CNMV teams to use this landing page and the linked source record to connect the reported facts to a concrete, proportionate action. We request assessment and lawful action—not acceptance of a predetermined finding of criminality, a blanket seizure or closure of lawful businesses.
The official register lists RIC PRIVATE EQUITY INVESTMENT PARTNERS, S.C.R., S.A., no.295, registered 25 October 2019. Registration does not establish misconduct, a listed-security nexus or the statutory intervention threshold.
CNMV · RIC PRIVATE EQUITY INVESTMENT PARTNERS, S.C.R., S.A. · 295
CNMV stated that the reported facts had been taken into account in its supervisory activity and invoked supervisory secrecy. The question is the scope, adequacy and next legally justified step—not an unsupported assertion that CNMV did nothing.
Existing RICPE source dossierIncoming 2026114903 / outgoing 2026149422: one additional month for the public-information decision because of volume and complexity. It is not a refusal, a merits decision or a decision to suspend all separate supervisory/preservation work.
PD-SP-EVT-0177 · Separate covering emailAssociate the new material with the existing record; identify the competent functional team and a secure channel for source files. Keep supervisory reporting, investor complaints and SAIP distinct.
Preserve relevant CNMV-held versions and correspondence. Assess targeted requirements for investment approvals, title/conditions, source-and-use, conflicts, Series F/G and subsequent transfers under the applicable information/inspection powers.
Compare available supervisory requirements, intervention or replacement under art.102/arts.72–75, and judicial protection requested under art.86.1(d). Identify the entity, evidence, risk, legal threshold and less disruptive effective alternatives.
Place concrete criminal indications and a specified digital-preservation schedule before the competent prosecution/judicial-police authority. LECrim 588 octies is their power, not CNMV’s. EPPO requires a qualifying EU-financial-interest nexus.
LECrim · arts. 105, 262, 282, 456, 544 quater, 588 octies, 589, 764, 803 ter · Ley 50/1981 · arts. 3–5, 19 · Ley 6/2023 · arts. 233, 243–244 · Regulation (EU) 2017/1939 · arts. 22–25, 31–32, 120
Design any justified measure around employees, guests, lawful suppliers, creditors and good-faith investors. Test liquidity, contracts, grant advances, costs and review rights; do not transfer business control to the complainant.
Código Penal · arts. 31 bis, 33.7(g), 109–129, 408 · Real Decreto 948/2015 · Ley 35/2003 · arts. 70–75 · Ley 38/2003 · arts. 14, 30, 32, 34.4, 35, 37, 44–49
If intervention/replacement is adopted, apply BOE publication and Registro Mercantil registration under art.73.3. Assess protective disclosure within art.243’s actual scope, and communicate the procedural information legally available without exposing reserved investigations.
Ley 35/2003 · arts. 70–75 · Ley 6/2023 · arts. 233, 243–244 · Ley 19/2013 · arts. 12, 14–16, 20, 24
This asks CNMV to assess action ex officio on supported information; it does not assert that Gil satisfies the specific shareholder/entity petition conditions of art.73.1. Any preferred rapid response interval is an operational request, not an invented statutory deadline.
It organises records, status, production, contrary evidence and dependencies. The public site is a map; every material proposition must return to its primary source.
It does not turn an alert into proved fraud, a registration into retrospective validation, a referral into a merits decision or supervisory secrecy into proof of inaction.
PROFESSIONAL READ · 7 MINUTES
The controlled record identifies filing 2021002141 of 13 January 2021 and later supervisory actions acknowledged by CNMV.
Reconstruct what was said about acquisition, title, encumbrances, investment and timetable, who approved it and what reservations existed.
54 CAM units, 190 LPB units and 18 third-party units; CAM acquisition future/conditional; unsigned LOI; full due diligence not started.
CAM filed the certification in Insolvency 36/2012. Purpose, authorisation, receipt and treatment should be identified.
Identify the new evidence, satisfied condition, waiver, valuation and decision that allowed the project to be reactivated.
The formal communication was submitted to RICPE and technically acknowledged by its platform. Admission, investigation, preservation, Board treatment and merits are not established.
CONTROL POINT
Fragmented ownership, future/conditional acquisition, unsigned LOI, full due diligence not started and prior withdrawal/conditionality.
Re-entry, later title within its exact perimeter, HNT, funding, Regional Incentives, ERDF and MYND operation. Each step needs its own record, decision-maker, date and boundary.
Rule: today’s operating hotel and later title do not retrospectively answer what was documented, verified, conditioned or corrected in 2020–2021.
COMPETENCE
DECISION TREE
Identify the policy, admission criterion, DD, valuation, conflict or condition.
Produce the primary record. If not, identify the contemporaneous deficiency.
Authority, reasons, limits, recusals, conditions and monitoring.
No issue, correction, requirement, preservation, referral or reasoned supervisory action.
MINIMUM SUFFICIENT PRODUCTION
Number control: the 20 September 2023 prospectus totals €6,570,713.56; a separate accounts reconstruction gives €6,573,703.10. The €2,989.54 difference remains open and is not normalised.
OPEN KIMONO · INSPIRATION AND WARNING
Opening the file does not mean disclosing supervisory secrets or protected data. It means being able to explain what entered, what was checked, what was missing, what contrary evidence was considered, which unit acted and what real status the matter reached.
Boundary: this list does not assert that CNMV or RICPE engaged in every negative practice. It offers a public, documentary and falsifiable test for the real file.
Series F/G control: Series F/G · suitability → separates the 2022–2023 administrative authorisation, source-specific amounts and use-of-funds questions without treating them as a fraud finding.
DEPENDENCIES
PUBLIC STATUS
The 17 August 2026 communication was submitted to RICPE. The planned later transmission to CNMV will not be described as sent, registered, acknowledged, examined or decided until the primary receipt proves each stage.
Official professional route: CNMV states that professional matters should be directed to the department competent for the subject through the “Any document, application or communication addressed to CNMV” electronic-office procedure. Official CNMV source →
PD-SP-ORION-NOTICE-20260905 · 2026-09-05
Every date links to its event and source. Sending, receipt, registration, incorporation, review and decision are different states. Commercial proximity and receipt of allegations do not transfer criminal responsibility. Due diligence and subsequent conduct are tested actor by actor.
PD-SP-EVT-0160A separate forward of the Orion complaint was sent to the CNMV information/reclamations route.
Sent-message evidence does not establish receipt, internal routing, review or acceptance of allegations.
PD-SP-EVT-0161Another distinct forward of the Orion complaint was sent to the CNMV complaints service.
This is a separate transmission, not a second underlying complaint finding or proof of examination.
PD-SP-EVT-0162A third separately timed forward was sent to the CNMV whistleblowing route used by the sender.
The outbound address alone does not prove that the communication entered a protected case, was examined, or established wrongdoing.
PD-SP-EVT-0171CNMV's later acknowledgement identifies a new RICPE communication sent on 20 August. This date-specific communication is registered from that recipient confirmation.
The complete native 20 August submission and attachment manifest have not been reconciled in this release. The acknowledgement does not establish acceptance of its allegations.
PD-SP-EVT-0173CNMV's signed decision records receipt on 25 August of public-information request 2026114903 covering RICPE/Sun Park/MYND source versions, Series F/G, conditions, conflicts, controls and advisers.
This is intake attested by the later decision, not a newly located standalone receipt. The relationship with the separately registered 24 August REGAGE event PD-SP-EVT-0152 is a reconciliation question, not assumed identity.
PD-SP-EVT-0175CNMV's infringement-reporting function acknowledged the new RICPE communication sent on 20 August.
Acknowledgement proves receipt, not investigation, an adverse finding, clearance, or a supervisory decision.
PD-SP-EVT-0177The signed CNMV decision extends the transparency-request response period by one additional month because of the volume and complexity of the information requested. The decision is separate from its covering email.
This is a deadline extension, not refusal of access, a substantive disclosure decision, refusal to investigate, clearance or finding on the allegations. The printed registry time has no stated timezone.
PD-SP-EVT-0178CNMV's transparency function transmitted the attached response to the request received on 25 August and asked Gil to acknowledge receipt.
This records the covering transmission only. Its unstated-zone timestamp is not directly comparable to the decision's printed registry time; no new merits conclusion or acknowledgment by Gil is inferred.
The forwards, infringement-reporting acknowledgement and transparency request are not collapsed into one proved case. The 4 September decision extends the deadline: it does not refuse access or decide the allegations.
20 individual events; six attachment descriptors. This is not a certificate of historical completeness.
Canonical communications register (JSON) · Source / event crosswalk
One connected factual inquiry with distinct criminal, civil, professional-discipline and recovery tests. Includes the 2022 recovery correspondence, 3 September pleading and July provisional dismissal; no assignment, guilt or stay is presumed. Read the sources, countercase and outstanding evidence.
INSTITUTIONAL FOLLOW-UP · 7 SEPTEMBER 2026
On 7 September 2026 a consolidated supplement was sent to CNMV concerning RICPE / Orion, the 2021 preventive alert, Aweswell's alleged current harm, subsequent financing, and requested preservation/protective measures. Dispatch was verified; dispatch does not prove substantive receipt, incorporation, investigation, sanction or an asset-protection order.
Separate follow-ups were sent the same day to Portfolio Stock Exchange, Ayuntamiento de Yaiza and Cabildo de Lanzarote. Cabildo was expressly asked to make a traceable internal referral to Tourism Planning and Classified Activities. A requested referral is not recorded as actual receipt until the receiving unit is evidenced.
Legal separation does not imply evidential irrelevance. RICPE financing, AGM management, Acosta Matos contracting and Orion governance/related-party disclosures may be directly relevant when testing financing, information, mandate, representation or benefit.
Direct relevance is not proof of asset transfer or shared liability. Those links alone do not establish Orion ownership of Sun Park or transfer of hotel assets, income or security to Orion.
Document rule: keep together the “under study” caveat, the 11 November 2020 webinar statements on purchase/title/charges, RICPE's 20 July 2021 certificate, CAM's 21 July 2021 court position, and the later financing/operation chronology. No one item automatically erases the others.
Cabildo / Tourism → · Portfolio / Orion → · Institutional records →