If you want Golden Visa exposure that behaves like a bond portfolio rather than a private-equity commitment, the 3CC Atlantic Bond Fund is one of the most liquid and best-documented options in our database. It offers daily NAV, daily redemptions and a published prospectus, KIIDs and monthly reports, at the cost of a flat 2.5% exit fee on any redemption inside five years. For US citizens, advertised SDIRA access and reported QEF availability strengthen the case, though two claims still need confirming in writing.
Key takeaways
- Open-ended, CMVM-authorized bond fund (no. 2249) launched June 2025, with €28M in assets as of June 2026 and daily dealing.
- At least 60% sits in bonds of Portuguese companies; the June 2026 book held 61.2% Portuguese debt plus international and Eurozone credit, 4.01% gold and 3.68% cash.
- Class EA costs €100,000 minimum, 1.50% entry, 1.50% management and a 10% performance fee above a 4% hurdle with a high-water mark.
- No lock-up, but a 2.5% exit fee applies to redemptions within five years of the initial subscription.
- The manager advertises SDIRA access for US investors; QEF reporting is reported in directory data but not yet confirmed in fund documents.
What does the fund actually invest in?
The mandate is 100% bonds: a minimum of 60% in corporate bonds of companies headquartered in Portugal, with the remainder in Eurozone investment-grade credit, international debt ETFs and a small gold allocation, per the manager's fund page and monthly reports. The stated objective is capital preservation and consistent income over a five-year horizon, not equity-style upside.
That 60% Portuguese floor is what keeps the fund inside the post-October 2023 Golden Visa rules, which require a non-real-estate collective investment vehicle with majority Portuguese exposure. The manager states the fund complies with AIMA regulations for the Residence Permit for Investment and holds no real estate.
The June 2026 fund report shows how the mandate translates into a live portfolio: 61.2% Portuguese debt, 23.07% international debt, 8.04% Euro debt, 4.01% alternative assets (gold) and 3.68% cash. Domestic issuers such as Novo Banco, REN and Fidelidade feature among the top holdings, which means the credit book leans toward Portuguese banking and utilities.
Two risk notes are worth reading before the fee table. Over half the book sits in BBB/BB-rated corporate debt, so this is credit risk, not a deposit substitute. And the gold sleeve, while small, adds commodity volatility to an otherwise fixed-income portfolio.
Which share class, and what do the fees cost you?
Three retail classes carry different minimums and fee mixes, and the differences matter more than they look:
| Class | Minimum | Entry fee | Management fee | Policy |
|---|---|---|---|---|
| EA | €100,000 | 1.50% | 1.50% | Accumulating |
| ED | €150,000 | 1.50% | 1.65% | Distributing |
| CD | €250,000 | 5.00% | 1.50% | Distributing |
To be precise: Classes EA and ED charge a 1.50% subscription fee, while Class CD charges 5.00%. Management fees run 1.50% per year for CD and EA and 1.65% for ED, with a 0.09% depositary fee charged separately. All classes share the same performance fee: 10% of returns above a 4% annual hurdle, with a high-water mark. Distributing classes pay annual income with reference to end-June.
Now the arithmetic on a €500,000 Golden Visa subscription in Class EA. Entry costs €7,500 at 1.50%. Management fees run about €7,500 per year, roughly €45,000 over six years or €52,500 over seven, before compounding effects. The depositary fee adds around €450 a year. All in, budget somewhere near €55,000 to €63,000 across a six-to-seven-year hold, before any performance fee.
The performance fee only bites above 4% per year. In a flat year you pay recurring costs only; in a strong year the manager takes a tenth of the excess, and the high-water mark stops you paying twice for the same gains.
One aggregator quirk we recorded: some directories list the minimum at €150,000, which corresponds to the Class ED minimum rather than the lowest class. The manager's own documents put Class EA at €100,000.
Liquidity, the exit fee and the citizenship timeline
There is no formal lock-up. The fund prices daily and processes subscriptions and redemptions daily, with an 11:00 London-time cut-off, per the prospectus and fund reports. What replaces a lock-up is a flat 2.5% exit fee on any redemption within the first five years after your initial subscription, falling to nil thereafter. On a €500,000 ticket, a year-three exit would cost about €12,500.
How does that map onto naturalization? In practice, the road from Golden Visa application to Portuguese citizenship tends to run roughly six to seven years once processing queues are counted. The fund's fee window clears at five years, comfortably inside that horizon, and because the vehicle is open-ended there is no fund maturity to wait for and no extension risk of the kind closed-end funds carry.
The binding constraint is legal rather than financial. Your qualifying €500,000 must stay invested while the Golden Visa is active, so your earliest sensible redemption date is set by your immigration timeline, not by the day the exit fee reaches zero. Plan the two together.
What should US citizens know?
More infrastructure than most Portuguese funds offer. The manager states it accepts US investors and advertises direct self-directed IRA (SDIRA) investment on its fund page. Directory data additionally records QEF reporting as available, which would matter enormously for the tax outcome: as a non-US pooled fund, this vehicle is a PFIC for US taxpayers, and a QEF election converts the punitive default regime into annual pass-through taxation.
Two US-facing claims need written confirmation before you wire anything. First, QEF reporting is recorded in directory data but not confirmed in the manager's own documents, so ask for the QEF information statement. Second, directory notes flag Regulation S limits: US citizens living abroad are explicitly permitted, while US residents may be restricted. Confirm how your residency is treated in the subscription documents.
FATCA reporting (Form 8938) and the annual PFIC form (8621) apply either way. In our experience, whether a fund actually delivers QEF statements often matters more to the after-tax result than small differences in headline fees, so settle it during diligence, not after.
How does it compare with other Golden Visa funds?
Within our database, this fund sits firmly at the liquid, conservative end. Its €100,000 Class EA minimum matches the typical entry ticket for open-ended Golden Visa funds, and the 1.50% management fee sits at the lower edge of the usual 1.5-2% range. The 10% performance fee over a 4% hurdle is gentler than the 20% carry structures common in closed-end vehicles, though the 1.50% entry fee is a real cost that some daily-liquidity peers do not charge.
Track record is the honest weakness. The fund launched on 18 June 2025 and held €28M as of June 2026, so it is both young and small. Class CD returned 1.05% cumulatively since inception, including a -0.21% first half of 2026. That is unexciting by design, but one year of data proves little either way. Past performance is no guide to the future, and capital is at risk.
The same manager runs the multi-asset 3CC Portugal Golden Income Fund, which adds equity and alternatives sleeves for investors who want more return potential with more volatility. For a same-category comparison, the ActiveCap Corporate Bond Fund runs a weekly-liquidity Portuguese bond strategy with no performance fee. The full comparison set is in our fund database.
What the fund has not published
A short, honest list. No target fund size is disclosed. The 4-6% per year return target comes from directory data; the manager's own materials state only an absolute-return objective without a figure. QEF reporting availability is not confirmed in manager documents. And the exact Regulation S treatment of US-resident subscribers, as opposed to US citizens living abroad, remains to be confirmed.
None of these is unusual for a young fund, and none is disqualifying. Their weight depends on your situation: each is a question to put to the manager in writing during subscription diligence.
Next step
If daily liquidity, a Portuguese credit portfolio and workable US mechanics match your plan, the sensible next move is a structured read of the prospectus and KIID rather than a leap. Roots can walk you through this fund's terms alongside comparable options, independently and without a sales agenda. Nothing here is investment, tax or immigration advice; it is information to make your own advised decision easier.
