The COCOO CaseLink Doctrine: Standard Model for the OCI Portal
Full URL: https://www.hacienda.gob.es/es-ES/SecretariaDeEstadoDeFuncionPublica/OficinaConflictoIntereses/Paginas/DeclaracionesdealtoscargosdelaAGE.aspx
Strategic Imperative
This portal, run by the Office of Conflict of Interests (OCI), is a critical resource for executing our “Challenge Discretionary Power” and “JR2COURT” (Judicial Review to Court) strategies. Its purpose is not to find companies, but to investigate the key public officials who make decisions that affect our cases—the ministers, secretaries of state, and heads of regulatory bodies.
The evidence found here provides leverage. A public official with an undeclared or problematic financial interest in a company or sector is compromised. We can use this information to:
- Challenge a public tender award where the decision-maker had a potential conflict.
- Question a regulator’s decision not to investigate a market (an “Enforcement Gap”), suggesting their impartiality is affected. 11111111111
- Add significant weight to a judicial review application, arguing that a decision was tainted by improper interests. 2222222
Part I: The Search Platform’s Rules & Functionality
This platform is not a conventional search engine with advanced operators. It is a public archive. Understanding its structure is key to using it effectively.
- No Dynamic Search Bar: There is no sitewide search function or advanced search form. You cannot search for keywords, company names, or asset types across all declarations simultaneously.
- Document-Based Architecture: The portal is organised chronologically by the date of an official’s appointment or cessation. The declarations are published as static PDF or HTML files linked next to the official’s name and title.
- Manual Investigation is Required: Accessing the information requires identifying the target individual first and then locating their specific declaration documents within the chronological lists. The “search” is therefore a manual, forensic process of document review.
- Information Available in Declarations: Each declaration typically includes:
- Real estate assets.
- Bank deposits and financial assets (shares, investment funds).
- Vehicles and other valuable assets.
- Liabilities (loans, mortgages).
Part II: The COCOO Strategic Forensic Protocol
This is the standard model for extracting actionable intelligence from the OCI portal.
Phase 1: Target Identification (External)
The work begins before visiting the OCI portal.
- Step 1.1: Identify the Decision-Maker: In any case involving a public body (e.g., a ministry, a regulator like the CNMC), identify the key senior official responsible for the decision in question. This could be the Minister, the Secretary of State, or the President of the regulatory agency.
- Step 1.2: Determine their Term of Office: Note the dates when this individual was appointed and when they left office. This is crucial for locating the correct documents on the OCI portal.
Phase 2: Document Retrieval and Analysis
- Step 2.1: Locate the Declaration: Navigate the OCI portal. The declarations are typically organised by government term (e.g., “XIV Legislatura”). Find the section corresponding to your target’s term of office.
- Step 2.2: Download All Relevant Files: Locate your target official in the list. Download both their initial declaration (made upon taking office) and their final declaration (made upon leaving office). The comparison between the two is often where the most valuable intelligence lies.
- Step 2.3: Forensic Document Review: This is the most critical step. Open the PDF files and manually search (using Ctrl+F or Cmd+F) for keywords relevant to your case. This includes:
- The names of key companies in the sector.
- The names of major investment funds known to be active in the sector. 333
- Keywords for asset types (e.g., the Spanish word for shares,
acciones).
Phase 3: Intelligence Synthesis and Leverage
- Step 3.1: Identify the Conflict: The goal is to find a direct or indirect financial link between the official’s declared assets and the matter we are investigating. For example, does the Minister for Ecological Transition hold a significant stake in a fund that heavily invests in a company that just won a major energy contract?
- Step 3.2: Compare Initial vs. Final Declarations: Analyse the change in the official’s wealth during their time in office. Was there a significant, unexplained increase in assets, particularly in funds or shares related to their portfolio?
- Step 3.3: Cross-Reference with Other Intelligence: Correlate the dates of significant asset purchases or sales in the declaration with key policy decisions or public contract awards.
- Step 3.4: Weaponise the Findings: The discovery of a conflict is a high-impact piece of evidence. It is not used for a broad public attack, but as a precise instrument in a formal submission to a court, a supervising body, or an anti-corruption prosecutor, arguing that a public decision is voidable due to a breach of impartiality.
Part III: Application to COCOO Doctrines
This forensic protocol is purpose-built to execute our most sophisticated strategies.
| Mind Map Doctrine | Application of the OCI Portal Protocol |
| Challenge Discrpower / JR2COURT | This is the primary application. Finding a conflict of interest is the “silver bullet” in a judicial review. It shifts the argument from a disagreement on policy to a question of procedural illegality and the integrity of the decision-maker, which courts take extremely seriously. 4444444 |
| CLP+WPI (Competition Law + Public Interest) | When challenging a merger or a state aid decision, demonstrating that the approving official had a personal financial interest aligns our commercial objectives with the public interest in clean governance, making our complaint politically potent. |
| USP (Unsolicited Proposal) | If we discover through our “Noisefilter” process that a public contract was awarded to a company linked to a decision-maker, we can use this evidence to challenge the award. The desired outcome is the cancellation of the tender, creating an opportunity for COCOO to propose a new, transparent process that we can mediate or bid for. 5 |
| PTW (Political Time Window) | Evidence of a conflict of interest has maximum impact when revealed during a sensitive political period, such as before an election or during a parliamentary hearing on the relevant department’s budget. The protocol requires timing the deployment of this intelligence for maximum effect. 6666 |