A new private equity fund will let overseas investors earn Portuguese and European Union citizenship by indirectly investing in Bitcoin, the project’s co-founder and CEO said last week.

Unbound Fund touts itself as the first “Web3 fund” to participate in Portugal’s golden visa program, which allows foreigners who invest a minimum of €500,000 (about $544,000 worth) in local companies or assets to gain residency status and EU citizenship without living in the country.

Golden visa programs grew in popularity during the COVID-19 pandemic but have raised concerns about security and money laundering and drawn criticism for driving up housing prices. In 2023, Portuguese officials announced plans to scrap their program entirely before choosing to continue it with real estate investments excluded.

Participating funds are required to keep at least 60% of their portfolios in Portuguese companies. To comply, Unbound Fund will transfer investments to domestic “special purpose vehicles” (SPVs) under the joint supervision of fund manager Green One Capital and fund advisor Unbound Capital, co-founder and CEO Alessandro Palombo told Decrypt.

The SPVs will then purchase Bitcoin ETF shares through BlackRock rather than buying and holding BTC directly—which Palombo tweeted was due to factors like “security and simplicity.” He elaborated to Decrypt that such golden visa funds come with “heavy regulatory requirements.”

Unbound investors must each buy shares worth at least €500,000 using fiat currency, Palombo said. He added that the fund’s operations would be subject to independent audits, and that Bitcoin price fluctuations will not affect investors’ golden visa eligibility—even if the value of their investment drops below €500,000.

Unbound registered as a private equity fund with the Portuguese Securities Market Commission (CMVM) on May 24, Palombo said. The fund is labeled “authorized” in the agency’s online database, although it is currently listed as inactive.

In an email to Decrypt, CMVM Press Officer Susana Domingos acknowledged that the “setting up of the fund, under the terms of the Asset Management Regime, depended on prior communication made to the CMVM,” and said the fund would operate under the agency’s supervision. 

However, she added that the fund “was not subject to a formal act of authorization” by CMVM and the eligibility of the fund’s investments for the golden visa program would be determined by the “competent authority responsible for granting golden visas, which is not CMVM.” 

The office that administers the golden visa program—the Portuguese Agency for Integration, Migration and Asylum (AIMA)—did not respond to requests for comment by the time of publication. 

Patricia Casaburi, CEO of investment migration consultancy Global Citizen Solutions, told Decrypt that the eligibility of funds that indirectly invest in Bitcoin, Bitcoin ETFs, or gold for the golden visa program “will depend upon AIMA’s reviews and analysis over time.” She added that her firm has 35 Portuguese golden visa funds in its portfolio covering a range of investments, and said she is aware of another crypto fund that is about to launch. 

Unbound’s lawyers, Lisbon-based law firm Morais Leitão, provided the fund with a legal opinion attesting to the fund’s eligibility, Palombo said.

The visa eligibility requirements for Unbound investors are no different than they would be with any other fund: The golden visa process requires proof of investment and biometric screening, among other things. Obtaining citizenship comes with its own stipulations, including a clean criminal record and passing a basic language test.

Portuguese golden visa holders must hold their investments for five years to become eligible for citizenship, during which time they must spend at least 14 days every two years in the country. Unbound investors will also have the option of using their own immigration lawyer or one furnished by the fund, Palombo said, noting that along with managing the investments, Unbound will assist investors with navigating the golden visa application process.

Palombo hopes Unbound will generate interest in Portugal among crypto investors and demonstrate crypto’s broader potential to facilitate “freedom of movement” around the globe.

Edited by Josh Quittner and Andrew Hayward