3 Comma Capital

3 Comma Capital oversees various regulated investment strategies that cover different levels of risk: the Portugal Golden Income Fund (a multi-asset fund for Golden Visas), the Atlantic Bond Fund (a safe fixed income option), the Global Crypto Fund (a regulated fund for digital assets that allows daily withdrawals), and the Unbound Fund (a venture capital fund focused on

The firm was built from the ground up as an independent, owner-managed SCR that bridges traditional fixed income with the digital economy. Its leadership combines experience managing more than €3.4 billion at one of Portugal’s largest asset managers with a long track record in alternative data, crypto, and venture capital, creating a rare blend of institutional discipline and innovation.

The structure of the Golden Visa-focused funds ensures that at least 60% of the capital invests in Portuguese-headquartered companies. The firm provides the specific confirmations required by AIMA and designs exit mechanisms around the five-year residence timeline, so investors can align their holding period with their immigration plan.

For multi-asset funds such as the Portugal Golden Income Fund, the core allocation is to investment-grade Portuguese corporate bonds, with smaller satellite allocations to global equities and digital assets. Crypto and gold are capped as a minority sleeve and used as a hedge and diversifier, while the Atlantic Bond Fund offers a pure bond alternative for investors who prefer zero crypto exposure.

The firm’s infrastructure allows daily NAV calculation and frequent dealing (daily or weekly, depending on the fund and share class). Golden Visa funds apply redemption fees that step down over time to encourage a full five-year holding period while still allowing earlier exits in emergencies. The Global Crypto Fund is designed for daily liquidity.

Traditional securities and cash are held with Bison Bank, a regulated Portuguese wealth-management bank, while digital assets are custodied with Gemini Trust Company in New York, using institutional cold-storage solutions. Independent audits by PwC and PKF verify fund valuations, and a bespoke Celfocus asset-management system automates reconciliations and reporting.

Investors include Portugal Golden Visa applicants seeking a capital-preservation route, high-net-worth individuals and family offices looking for regulated crypto exposure, and sophisticated investors interested in venture capital opportunities in Portugal’s Web3 ecosystem. Many value the ability to combine conservative bond strategies with carefully managed growth assets under one regulated manager.

The firm currently classifies its funds as Article 6 under the EU SFDR, meaning they do not market themselves as dedicated ESG products. This reflects the practical challenges of obtaining robust sustainability data for early-stage startups and digital assets. However, 3 Comma Capital applies internal ESG guidelines and reviews its classification regularly as data quality in these sectors improves.