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Do I need to open a Portuguese bank account to make my Golden Visa investment?

Residencies & citizenships Portugal Golden Visa 🇵🇹
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Opening a Portuguese bank account is not strictly mandatory for transferring funds for a Golden Visa investment.

The primary legal requirement, as outlined in paragraph 11 of article 65-D of Decree-Law 84/2007, is to prove that the funds originate from abroad. While obtaining a declaration from the Investor’s bank is the standard method to fulfill this requirement, alternative measures are increasingly being used.

A Portuguese bank account serves as more than just a way of transferring funds, since it is also key for proving the movement of capital. Having a personal account provides direct oversight of funds and transactions as well as simplified management of expenses.

In addition to this, the Investor takes immediate “ownership” of the investment, as the Units of Participation will be deposited in the account, and they have flexibility in managing ongoing or future transactions related to the investment.

Unfortunately, opening a bank account has become a lengthy and bureaucratic process. Due to stricter Bank of Portugal regulations, Investors now face more extensive documentation requirements in addition to proof of identity, proof of address, a Portuguese taxpayer number (NIF), financial statements from the country of origin, and detailed evidence of the origin of funds. What can also complicate the process is that most of these documents need to be duly legalized with an apostille or certification from the Portuguese Embassy of the issuing country.

Following these checks, banks perform rigorous and extended compliance reviews, which often take 3-4 months, largely due to inefficiencies in the banking system rather than genuine security concerns. These delays can expose investors to risks such as changes to the Golden Visa program and missed opportunities, especially since the timeline to Portuguese citizenship now begins at the date of application submission.

Given the delays in opening personal bank accounts, alternative methods have emerged to streamline the process while maintaining compliance with Portuguese law. These are:

Jumbo Bank Accounts from Investment Funds

Some investment funds now offer a shared “jumbo” account option, or an omnibus account held by the management company on behalf of clients, allowing Investors to transfer funds directly to a centralized account. Clients then open an account of Register and Deposit of Participation Units (shares) of the fund they subscribe.

This innovative solution speeds up the process while ensuring compliance, as the fund itself is responsible for the Know Your Customer (KYC) and anti-money laundering (AML) procedures.

Advantages:

  1. Faster processing times
  2. Simplified transfer process for Investors
  3. Avoid banking costs, which include significant declaration issue costs or maintenance fees
  4. Postponing the Portuguese bank account opening until it can be done in person, when visiting the country, which will be quicker

Disadvantages:

  1. Potential risk of “putting all the eggs in one basket” if issues arise with the fund, especially for funds that are not diversified
  2. Payments in Portugal have to be done through your foreign bank, which may carry high foreign exchange fees

Law firm-managed client account

This method has been in use since the Golden Visa program’s inception. Law Firms can act as intermediaries by providing a client-specific bank account to bridge funds between the Investor and the chosen investment.

How it works:

  1. The Investor engages a reliable Law Firm for their Golden Visa process.
  2. An agreement is signed, detailing the use of the escrow account and instructions for the investment.
  3. The Investor transfers funds to the Law Firm’s bank account.
  4. The Law Firm completes the investment on behalf of the client.
  5. The bank issues a declaration confirming the funds originated from abroad and were used for a specific investment.
  6. The investment fund issues a declaration confirming the investment and its allocation to the Investor (e.g., Units of Participation).

This process complies with legal requirements, and many Golden Visa applications have been successfully processed using this method. Additionally, Investors can temporarily use the Law Firm’s account for holding their investment until their personal bank account is opened, if necessary.

Advantages:

  1. Well-established and proven method;
  2. Dual compliance ensured by both the bank and the Law Firm;
  3. Flexible custody options while awaiting a personal bank account.

Limitations:

  1. Requires trust in the Law Firm managing the funds;
  2. Not all the Law Firms offer this option for their clients.

Conclusion

While opening a Portuguese bank account remains the traditional route, alternatives such as jumbo bank accounts and Law Firm-managed client accounts provide practical and legally compliant options for Investors facing delays or other challenges. These solutions ensure timely investments, maintain compliance with anti-money laundering laws, and keep the Golden Visa process on track.

For Investors navigating these complexities, professional guidance from experienced legal advisors is crucial to choosing the right path.

If you have additional questions on this topic, feel free to post them below or reach out directly.

This is a companion discussion topic for the original entry at https://nomadgate.com/portugal/legal-questions/portugal-golden-visa-bank-account-requirement
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Thank you for your thorough explanation!

Is something like what is explained in this post (investing directly in a fund from a self-directed IRA) enabled by the relevant fund having an omnibus account?

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I believe so, the funds offered are mutual funds and one of them is qualified for GV. I think they are kind of like Dodge & Cox in the US, best description I can come up with. We have not completed the process yet, I can let you know more how it all goes, steps we took etc, once investment is complete & GV application submitted if you would like.

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I have completed my investment with Optimize using my Self Directed IRA and no LLC. The key factor from the SDIRA side was that the fund is Not Publicly Traded, thus the investment could be made directly. It was important on the Optimize side that the wire transfer included my full name as it appears on their account/GV application. This was an issue as at first the SDIRA sent it out with just my last name as the reference, despite the phone calls and emails from mself and Optimize spoke with them directly explaining the important on the name! (I can tell you more about that nightmare if you wish) However, the process works much the same as conducting a roll-over from one retirement account to another, but of course it is still tied to my SDIRA. Optimize then send the Declaration needed for the GV application. I am not sure that other similar companies can do this portion or not. But this is what made it possible to do it directly, no Portuguese bank account was needed.
So, the questions to ask the SDIRA firms is “Can I make an investment directly (no LLC) into a Non Publicly Traded Fund in Portugal?” In my case Optimize even provided a statement stating this directly to my SDIRA , though it is in their prospectus too, to calm any concerns. Also, apparently not all SDIRA firms can do this, so it is important to ask and establish they can do exactly what you are needing before rolling your retirement to them.
The question to ask the fund manager is Confirm this is Not Publicly Traded, and that they can accept the funds directly from the SDIRA- they have the capacity to act as the bank on the Portuguese side, and that they will issue the Declaration.
Also, I cannot say enough good things about Optimize and the level of service and assistance in general I have received.
Our application was submitted this week.

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As a data point, I just opened up a bank account with Bison Bank. It took 2 weeks to open. Once opened, it took 3 days for the wire to come through, and then about a week for the investment transfers to complete and show up in the account. All in, it was about 1.5 months from engaging a lawyer to application submission.

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Thank you so much for this post. It’s incredibly helpful. Can you tell me whether you worked with a golden visa company like Global Citizen Solutions, or if you worked directly with Optimize and an immigration attorney? Also, when working with Optimize, did an attorney or financial advisor assist with that or did you do that all yourself? Thanks!

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Thank you for the valuable information about investing directly in a Portuguese fund without having to establish an LLC. Do you have any suggestions on an SDIRA firm or firms that are easy to work with to do this? I’m starting from scratch! Thanks again.

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I worked directly with Optimize- they were great! My attorneys are at NSM and they handled getting our application submitted. Optimize sent the needed bank declaration to NSM. NSM and Optimize are both very responsive, experienced and helpful!

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Hello,
You will want to question any SDIRA in detail, that they will be able to make the investment directly on your behalf. They will all tell you they can help you with investment because it can be done with the LLC situation. You want them to wire the money with the “FBO” (For the Benefit Of) and YOUR NAME to the fund.
Not all will do this or perhaps realize it can be done? The key aspect when I did this was that the fund was Not Publicly Traded.
Some of these companies charge a lot, which is ridiculous because all they do is wire the money and then after that they send you the forms for the end of the year, where You actually complete the value of your investment. I found one and it was about $500 year after a 1x account set up fee of about $450, I think.

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Thank you so much! That is super helpful!

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Does anyone know of other funds besides Optimize that permit direct deposits from your US bank without having a Portuguese bank account?

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Thank you so much for your reply. We just found an SDIRA custodian who will work with us and the Optimize Fund. Your posts have been so helpful to us—thank you again.

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curious as to who is the SDIRA custodian?

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Thank you so much for this. I’m hoping to use an IRA for my investment. Could you share the contact information for the person at Optimize who helped you with this? That could hopefully make the process much easier for me. Thank you in advance!

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IRA Financial

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Since Portuguese banks have arbitrarily frozen a lot of Golden Visa investors’ accounts, I wonder if an fund manager such as Optimize could directly wire the money to investors’ overseas accounts when we redeem the funds?

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They have frozen the investors accounts? That is news to me? What is the source?

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@Tatley Which SDIRA custodian did you choose?

@mgayle I looked into IRA financial that your used. Did you choose the SDIRA without LLC, or with LLC?

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@mgayle Due to the type of GV investment option I chose, I did not need to have an LLC. Make sure that the investment manager of the GV fund has the capacity to accept funds directly from the US SDIRA, AND issue the Bank Declaration for the GV. I was able to this in January with Optimize.