While I have limited knowledge of the facts in this situation, I am concerned about the possibility that AffCom is insufficiently investigating facts before making judgments.
Interventions from Affcom which are undertaken with an insufficient knowledge of the facts risk doing more harm than good.
I encourage AffCom and WMF to consider whether improving AffCom's capacity to independently investigate the facts of affiliates' situations should be increased, for example by authorizing AffCom to contract with legal counsel who are licensed to practice in countries where AffCom has concerns and who can independently investigate the facts of affiliates' situations on AffCom's behalf.
Another difficulty with this situation is AffCom's lack of transparency. If AffCom was more transparent about its investigations and actions then outsiders would be able to better understand AffCom's work and evaluate AffCom's actions. Because AffCom withholds so much information, it is difficult to say whether AffCom is right or wrong with regards to Wikimedia Portugal. What I can say is that the lack of transparency, in my opinion, is a problem, is a poor governance practice, and is difficult to reconcile with the open source nature of Wikimedia.
I don't want to underestimate the challenge of evaluating compliance of Wikimedia affiliates around the world. This a big job, and if AffCom members volunteer their time in good faith and valuable relevant skills then I'm grateful for that. But I have some concerns about AffCom regarding transparency, investigative capacity, investigative skills, and adjudicative process.