The Unbound Fund is the most explicitly Bitcoin-focused vehicle on the Portugal Golden Visa fund route in our database: a closed-end alternative investment fund buying stakes in Portuguese Bitcoin-ecosystem companies, plus up to 40% direct exposure to Bitcoin or Bitcoin ETFs. Terms are unusually simple, no entry or exit fees, 1.5% management, 10% carry. The trade-offs are equally clear: an 8-year lock-up, KIID risk class 6 of 7, and a directory listing that mislabels it as open-ended.
Key takeaways
- Closed-end alternative fund, CMVM authorization no. 2089, investing at least 60% in Portugal-registered Bitcoin-ecosystem companies with up to 40% in Bitcoin or Bitcoin ETFs.
- €100,000 fund minimum; Golden Visa applicants need a €500,000 subscription. No entry or exit fees, 1.5% annual management fee, 10% performance fee on gains.
- 8-year term with no ordinary redemption before liquidation; a popular directory wrongly describes it as open-ended with monthly redemptions.
- Managed by 3 Comma Capital since April 2025, after a transfer from Green One Capital; Bison Bank is depositary, BDO audits.
- US acceptance, PFIC/QEF treatment, current AUM and portfolio composition are not published. KIID scenarios run from total loss to +79% per year.
What does the fund actually invest in?
The mandate targets new and existing companies in the Bitcoin ecosystem: mining, staking, blockchain protocol development, research, liquidity provision and software development, per the management regulation and KIID. A defining feature is that portfolio companies hold their capital reserves predominantly in Bitcoin and other highly liquid crypto assets. On top of the equity book, the fund may hold up to 40% direct exposure to Bitcoin, either outright or through ETFs and funds with predominant Bitcoin exposure.
Two hard constraints shape the rest. At least 60% of investments must sit in companies registered in Portugal, which is what keeps the fund inside the post-October 2023 Golden Visa rules. And the management regulation prohibits any direct or indirect real estate exposure, with no leverage permitted either.
The practical effect is a single-thesis vehicle. You are exposed to Bitcoin price and mining economics twice over: once through the portfolio companies' operations, and again through their crypto-heavy treasuries and the direct Bitcoin sleeve. The KIID classifies risk at 6 of 7, and its performance scenarios, built on a Bitcoin-mining discounted cash flow model, range from total loss to +79% per year. Those are illustrations, not targets; the fund publishes no target return. Capital is at risk, and past or modelled performance does not predict future results.
What do the fees cost you over a Golden Visa hold?
The fee schedule is one of the cleaner ones we have catalogued. There is no subscription fee and no exit fee. The management fee is 1.5% per year, calculated daily on subscribed capital during the four-year investment period and on paid-up capital during divestment. A depositary fee of 0.09% per year (minimum €1,800) comes on top, and the KIID puts the total annual cost impact at roughly 1.53%.
Now the arithmetic on a €500,000 Golden Visa subscription. At 1.5%, management fees run €7,500 per year, roughly €45,000 over six years and €52,500 over seven. Using the KIID's 1.53% all-in estimate instead, budget about €7,650 per year, or €46,000 to €54,000 across a six-to-seven-year window. Since the fund's term is eight years and you cannot ordinarily exit early, the realistic full-term cost at 1.53% is closer to €61,000 before any performance fee.
The performance fee is 10% of gains, structured as a 90/10 split. At liquidation, everything above investors' subscribed capital is shared 90% to investors and 10% to the manager, with no hurdle. During the fund's life, annual distributions on the same split are only permitted if the fund has achieved a cumulative 10% per year return on assets. In other words, the 10% hurdle gates interim payouts, not the final carry.
Liquidity, lock-up and the citizenship timeline
This is a closed-end fund with an 8-year duration: a four-year investment period followed by divestment. Units cannot be redeemed before liquidation except in legally provided cases, such as voting against a term extension or a merger. A secondary sale to another investor is possible, but only with the manager's approval. The term is extendable one or more times by one year each via unit-holder resolution, and the investment period itself can be extended by two years; dissenting unit holders may redeem in cash on extension.
One widely used fund directory describes this fund as open-ended with monthly redemptions. The fund's own KIID, dated 2 October 2025, is explicit that it is a closed alternative investment fund with no redemptions before the end of the 8-year term except in cases provided by law. The fund documents prevail. If monthly liquidity is part of your plan, this is not the structure you are buying.
How does eight years map onto citizenship? In practice, the road from Golden Visa application to naturalization tends to run roughly six to seven years once processing queues are counted, and the qualifying €500,000 must remain invested while the visa is active. An 8-year term covers that period without forcing a decision, which some applicants will see as a feature. The cost is optionality: if circumstances change in year three, there is no redemption window, and extension resolutions could stretch the wait further.
One related gap is worth noting. The fund's CMVM prior registration dates to 24 May 2024, and the manager still lists monthly subscriptions with a monthly NAV chart, but whether the original 24-month subscription window has closed or been extended is not published. The management regulation itself only guarantees unit-value communication at least annually, so treat the monthly NAV cadence as reported rather than contractual.
What should US citizens know?
Less than usual, because the fund publishes nothing on the topic. There is no public statement on whether US investors are accepted, no disclosed PFIC status, no word on QEF reporting, and nothing on IRA eligibility. As a non-US pooled fund holding Bitcoin-linked companies, it would be expected to be a PFIC for US tax purposes.
That expectation matters. Under the default PFIC regime, gains can be taxed at top ordinary rates plus an interest charge; a QEF election, which requires the fund to issue annual information statements, usually produces a materially better outcome. Whether 3 Comma Capital provides those statements for this fund is simply unknown. In our experience, that single question can outweigh the entire fee discussion, so put it to the manager in writing, and note that the same manager does advertise US-investor infrastructure on other vehicles, which makes a direct ask worthwhile. FATCA reporting (Form 8938) and Form 8621 apply to US holders either way.
How does it compare with other Golden Visa funds?
Within our database, the Unbound Fund occupies a genuine niche: no other vehicle we track is this explicitly Bitcoin-first. Its €100,000 minimum matches the typical Golden Visa fund entry ticket, and the 1.5% management fee sits at the bottom of the usual 1.5-2% range, with the 10% carry lighter than the 20% many closed-end funds charge. What you give up is liquidity and diversification: this is an 8-year, single-sector commitment with a maximum initial capital of €30 million per the management regulation, although one directory markets a €100 million ambition that the fund documents do not support.
The manager is young too. 3 Comma Capital was licensed in 2023, the fund dates from 2024, and management has already been transferred once, from Green One Capital in April 2025, with the vehicle transformed from a closed venture capital fund into a closed alternative investment fund in October 2025. None of this is unusual for a first-generation crypto fund, but it means there is no long institutional track record to lean on.
If you want digital-asset exposure blended with a broader portfolio instead, the Horizon Fund pairs Portuguese bonds with a crypto sleeve. For the same manager in a much more conservative wrapper, the 3CC Portugal Golden Income Fund runs a bond-led, daily-liquidity mandate. The full set is in our fund database.
What the fund has not published
For completeness, here is what remains undisclosed; how much each gap matters depends on your own situation. Current subscribed capital and AUM are not published. The NAV track record since inception was not retrievable from the manager's static fund page, so there is no verifiable performance history yet. Portfolio composition, the number and identity of investee companies, is not published. US investor acceptance, PFIC status and QEF reporting are unconfirmed. And it is unclear whether the original subscription window from May 2024 has closed or been extended.
Each of these is a reasonable written question for 3 Comma Capital during subscription diligence, and the answers belong in your file before any wire.
Next step
If a CMVM-regulated Bitcoin thesis inside the Golden Visa wrapper is specifically what you are after, and you can hold an illiquid position for eight years with total loss as a modelled scenario, this fund's documents deserve a careful read. Roots can walk you through the management regulation and KIID alongside comparable options, independently and without a sales agenda. This is information, not investment, tax or immigration advice; capital is at risk.
