PANTERA VENTURE FUND III SEC REVIEW 2026
INDEPENDENT VERDICT
Pantera Venture Fund III is a mature 2018-vintage blockchain venture strategy whose public regulatory footprint is considerably more complex than a single $175 million fund-size headline suggests. Pantera's official website describes Venture Fund III as a closed $175 million vehicle launched in 2018 with 32 investments, focused on companies enabling the institutionalization of digital assets. The SEC record, however, shows at least two legally distinct Fund III vehicles. Pantera Venture Fund III LP, CIK 0001732380, filed its latest amendment on August 11, 2026 and reported $206,412,931 cumulatively sold since a July 31, 2018 first sale. Pantera Venture Fund III A LP, CIK 0001751437, filed a further amendment on September 18, 2026 and reported $16,751,356 cumulatively sold to 78 investors since September 13, 2018. Both are Delaware limited partnerships, both identify Pantera Venture III GP LLC as General Partner, and both now operate from 600 Montgomery Street, Suite 4500, San Francisco. The arithmetic total of their current Form D sales is approximately $223.16 million, but that number should not be presented as current Fund III NAV or mechanically compared with Pantera's official $175 million fund-size figure without understanding subscriptions, parallel-vehicle mechanics and historical capital accounting.
The two vehicles also reveal a meaningful structural distinction. The main Pantera Venture Fund III LP currently relies on Rule 506(c) and Section 3(c)(7), while Pantera Venture Fund III A LP also relies on Rule 506(c) but claims Section 3(c)(1). The main vehicle reported 224 investors in its 2025 and 2026 filings and $206.41 million cumulatively sold; the A vehicle currently reports 78 investors and $16.75 million sold. Both report indefinite offerings and a $0 Form D minimum, and both state that management fees are described in their private offering documents. Pantera Capital Partners LP is identified as the management company in the current filings, while SEC investment-adviser records separately identify Pantera Capital Management LP as filing adviser for Pantera Venture Fund III LP and list Pantera Venture III GP LLC as General Partner. These overlapping Pantera entities should not be collapsed into one name: the fund issuer, General Partner, management-company promoter and registered investment adviser perform different legal roles. The 3(c)(7) versus 3(c)(1) distinction also strongly suggests that the main and A vehicles serve different investor or structuring needs even though they participate in the same Fund III franchise.
The investment thesis is unusually easy to verify from Pantera's own historical materials. Pantera says it launched the first blockchain-only venture fund in 2013, followed with Venture Fund II in 2014 and launched Fund III in 2018 specifically to back businesses supporting the institutionalization of digital assets. Pantera later confirmed that Fund III invested in Alchemy, the blockchain infrastructure company for which Pantera led a $15 million Series A in 2019. Historical Pantera LP-event materials also featured companies including Bakkt, BitGo, Brave, StarkWare, Alchemy and Staked, illustrating the type of exchange, custody, infrastructure, developer-tooling and blockchain-application businesses surrounding the firm's venture strategy, although those event lists should not be interpreted as proof that every company was owned by Fund III. Pantera's current firm page reports that its venture funds collectively have realized $547 million on $137 million of invested capital across 40 companies and that Pantera has led roughly half of 210 investments since 2013. Those are firmwide venture statistics, not Fund III performance, but they provide useful evidence that the manager's venture platform has generated actual realizations rather than existing only as unrealized crypto-company marks.
Fund III is also distinct from Pantera's later vehicles. Pantera describes Venture Fund I as a $12 million, eight-investment vehicle focused on businesses enabling users to buy, store and speculate on Bitcoin; Fund II as a $23 million, 36-investment vehicle focused on cross-border payments, regional exchanges and developer tools; Fund III as the $175 million, 32-investment institutionalization strategy; and Blockchain Fund IV as a much larger $1.25 billion, 80-investment vehicle combining venture equity, early-stage tokens and liquid tokens. Pantera has since marketed Fund V as another broad venture-style strategy spanning blockchain asset types. This progression matters because investors should not attribute Blockchain Fund IV or Fund V portfolio companies, token allocations or current fundraising activity to Venture Fund III. Fund III is an older, closed vintage whose economics increasingly depend on realization timing, secondary-market exits, IPOs, acquisitions and distributions from companies originally backed during the 2018-2021 crypto venture cycle.
The core diligence issue in 2026 is therefore valuation and liquidity rather than identity. Venture Fund III has now existed for roughly eight years, meaning investors should be asking how much of its current value remains unrealized, which companies still dominate NAV, what portions have been distributed, how portfolio marks were affected by the 2022-2023 crypto downturn, how subsequent financings changed ownership percentages, and whether major winners offset companies that failed or were written down. Pantera's public record provides unusually strong evidence of manager continuity, Fund III's original strategy and at least one specific Fund III investment in Alchemy. But neither Form D nor the public website supplies current Fund III NAV, DPI, TVPI, IRR, loss ratio, remaining portfolio value, individual company carrying values or LP-level cash flows. Those figures—not the $206.4 million cumulative Form D amount, the $16.75 million A-vehicle amount or Pantera's firmwide realization statistics—are the correct evidence for evaluating the fund's actual investment outcome.
SEC SNAPSHOT — MAIN VEHICLE
SEC FILE NUMBER: 021-319371 LATEST FORM D/A: August 11, 2026 YEAR FORMED: 2018 FUND CLASSIFICATION: Private Equity Fund SECURITY TYPE: Pooled Investment Fund Interests FEDERAL EXEMPTION: Rule 506(c) OFFERING DURATION: More than one year LATEST CUMULATIVE AMOUNT SOLD: $206,412,931 LATEST REPORTED INVESTORS: 224 FORM D MINIMUM INVESTMENT: $0 SALES COMMISSIONS: $0 FINDERS' FEES: $0 CURRENT NAV: Declined to disclose MANAGEMENT COMPANY / PROMOTER: Pantera Capital Partners LP MANAGING PERSON: Daniel W. Morehead PARTNER: Matthew Gorham CHIEF COMPLIANCE OFFICER / CHIEF LEGAL OFFICER: Katrina Paglia CHIEF FINANCIAL OFFICER: Marc Selfon
SEC SNAPSHOT — PARALLEL A VEHICLE
SEC FILE NUMBER: 021-322252 LATEST FORM D/A: September 18, 2026 YEAR FORMED: 2018 FUND CLASSIFICATION: Private Equity Fund SECURITY TYPE: Pooled Investment Fund Interests FEDERAL EXEMPTION: Rule 506(c) OFFERING DURATION: More than one year LATEST CUMULATIVE AMOUNT SOLD: $16,751,356 LATEST REPORTED INVESTORS: 78 FORM D MINIMUM INVESTMENT: $0 SALES COMMISSIONS: $0 FINDERS' FEES: $0 RELATED-PERSON USE OF PROCEEDS REPORTED: $0 CURRENT NAV: Declined to disclose MANAGEMENT COMPANY / PROMOTER: Pantera Capital Partners LP 2026 FORM D SIGNER: Katrina Paglia SIGNER TITLE: Chief Compliance Officer & Chief Legal Officer
PARALLEL-VEHICLE CAPITAL ANALYSIS
MAIN LP CUMULATIVE SOLD: $206,412,931 FUND III A CUMULATIVE SOLD: $16,751,356 ARITHMETIC TOTAL: $223,164,287 OFFICIAL PANTERA FUND III SIZE: $175,000,000 IMPORTANT: $223.16M is an arithmetic combination of cumulative Form D sales from two separate issuers IMPORTANT: $223.16M is not verified current NAV IMPORTANT: $223.16M should not be described as Pantera's official Fund III size IMPORTANT: $175M is Pantera's own published Fund III size IMPORTANT: Form D cumulative subscriptions and manager-reported fund size can measure different capital concepts IMPORTANT: Redemptions, transfers, distributions, recycling and historical parallel-vehicle accounting can make headline figures differ IMPORTANT: Do not "correct" Pantera's $175M figure by replacing it with $223.16M without partnership documents
FORM D HISTORY — MAIN FUND
2018 REPORTED SOLD: $71,445,000 2019 REPORTED SOLD: $95,864,455 2020 REPORTED SOLD: $164,705,834 2021 REPORTED SOLD: $170,246,873 2022 REPORTED SOLD: $211,774,899 2023 REPORTED SOLD: $206,395,855 2024 REPORTED SOLD: $206,412,931 2025 REPORTED SOLD: $206,412,931 2026 REPORTED SOLD: $206,412,931 IMPORTANT: The decline from 2022 to 2023 demonstrates why Form D figures should not simply be treated as irreversible committed-capital totals IMPORTANT: Historical Form D amounts must not be added together
FORM D HISTORY — A VEHICLE
2026 REPORTED SOLD: $16,751,356 2026 INVESTORS: 78 OFFERING: Indefinite CURRENT SALES INCREASE FROM PRIOR YEAR: $0 in current filing index IMPORTANT: Continuing Form D amendments do not imply new fundraising each year
ADVISER / MANAGER STRUCTURE
FILING ADVISER IDENTIFIED IN SEC ADV RECORDS: Pantera Capital Management LP MANAGEMENT COMPANY NAMED IN CURRENT FORM D: Pantera Capital Partners LP FOUNDER: Daniel W. Morehead PANTERA FOUNDED: 2003 BLOCKCHAIN INVESTING LAUNCHED: 2013 CURRENT PRIMARY FUND OFFICE: San Francisco ADDITIONAL PANTERA LOCATIONS: New York and Puerto Rico PRIVATE FUND ID FOR MAIN FUND IN ADV: 805-8320850481 IMPORTANT: Pantera Capital Management LP, Pantera Capital Partners LP and Pantera Venture III GP LLC are related but legally distinct entities
PANTERA VENTURE FUND III STRATEGY
OFFICIAL FUND NAME: Venture Fund III VINTAGE: 2018 OFFICIAL FUND SIZE: $175 million OFFICIAL INVESTMENT COUNT: 32 STATUS: Funding Closed PRIMARY OBJECTIVE: Back companies enabling institutionalization of digital assets PRIMARY SECURITY TYPE: Private company equity INVESTMENT STAGE: Multi-stage venture CORE THEMES: Blockchain infrastructure; custody; exchanges; payments; developer infrastructure; institutional digital-asset services ILLIQUIDITY PROFILE: Long-duration private venture capital TOKEN EXPOSURE: Should not be assumed from later Pantera funds CURRENT PORTFOLIO SCHEDULE: NOT PUBLICLY DISCLOSED CURRENT NAV: NOT PUBLICLY DISCLOSED CURRENT DPI: NOT PUBLICLY DISCLOSED CURRENT TVPI: NOT PUBLICLY DISCLOSED CURRENT NET IRR: NOT PUBLICLY DISCLOSED
CONFIRMED FUND III PORTFOLIO EVIDENCE
PORTFOLIO COMPANY: Alchemy BUSINESS: Blockchain infrastructure and developer tools FUND III PARTICIPATION: Explicitly confirmed by Pantera FINANCING: $15 million Series A ROUND TIMING: 2019 PANTERA ROLE: Lead investor INVESTMENT THESIS: Infrastructure allowing developers to build blockchain applications without operating their own underlying node infrastructure CURRENT FUND III FAIR VALUE OF ALCHEMY: NOT PUBLICLY DISCLOSED CURRENT FUND III OWNERSHIP PERCENTAGE: NOT PUBLICLY DISCLOSED CURRENT REALIZED / UNREALIZED STATUS: REQUIRES FUND REPORTING
HISTORICAL PANTERA VENTURE ECOSYSTEM EVIDENCE
BAKKT: Featured in Pantera venture portfolio-company LP programming BRAVE: Featured in Pantera venture portfolio-company LP programming BITGO: Featured in Pantera venture portfolio-company LP programming STARKWARE: Featured in Pantera venture portfolio-company LP programming ALCHEMY: Featured and independently confirmed as Fund III investment STAKED: Featured in Pantera venture portfolio-company LP programming IMPORTANT: Appearance in Pantera portfolio events does not prove ownership by Fund III specifically IMPORTANT: Portfolio attribution must be made from fund-specific Pantera disclosures where possible
PANTERA VENTURE FUND EVOLUTION
VENTURE FUND I VINTAGE: 2013 VENTURE FUND I SIZE: $12 million VENTURE FUND I INVESTMENTS: 8 VENTURE FUND I FOCUS: Bitcoin access, storage and speculation infrastructure
VENTURE FUND II VINTAGE: 2014 VENTURE FUND II SIZE: $23 million VENTURE FUND II INVESTMENTS: 36 VENTURE FUND II FOCUS: Cross-border payments; regional exchanges; developer tools
VENTURE FUND III VINTAGE: 2018 VENTURE FUND III SIZE: $175 million VENTURE FUND III INVESTMENTS: 32 VENTURE FUND III FOCUS: Institutionalization of digital assets
BLOCKCHAIN FUND IV VINTAGE: 2021 BLOCKCHAIN FUND IV SIZE: $1.25 billion BLOCKCHAIN FUND IV INVESTMENTS: 80 BLOCKCHAIN FUND IV FOCUS: Venture equity; early-stage tokens; liquid tokens
FUND V: Separate successor venture-style strategy IMPORTANT: Fund IV and Fund V holdings, tokens and fundraising should not be attributed to Fund III
PANTERA FIRM OPERATING EVIDENCE
PANTERA FOUNDING YEAR: 2003 FOUNDER: Daniel Morehead FORMER ROLE OF FOUNDER: Tiger Management Head of Macro Trading and CFO FIRST U.S. BLOCKCHAIN HEDGE / VENTURE FUNDS: Pantera states 2013 VENTURE REALIZATIONS REPORTED BY PANTERA: $547 million INVESTED CAPITAL ASSOCIATED WITH REPORTED REALIZATIONS: $137 million COMPANIES ASSOCIATED WITH REPORTED REALIZATIONS: 40 TOTAL PANTERA INVESTMENTS SINCE 2013: Approximately 210 SHARE OF INVESTMENTS LED BY PANTERA: Approximately one-half according to Pantera IMPORTANT: These are platform-wide statistics and are not Fund III performance
REALIZATION / EXIT CONTEXT
CIRCLE: Long-running Pantera investment that completed a NYSE IPO in 2025 PANTERA INITIAL CIRCLE INVESTMENT: Series B in 2014 according to Pantera CIRCLE RELATIONSHIP: Predates Fund III and should not automatically be attributed to Fund III 2025 BROADER PANTERA PUBLIC LISTINGS REFERENCED BY FIRM: Circle; Amber; Figure M&A EXAMPLE DISCUSSED BY PANTERA: Stripe acquisition of Bridge SIGNIFICANCE: Demonstrates improving exit channels for blockchain venture portfolios IMPORTANT: Firm-level exits do not establish Fund III-specific DPI or returns
WEBSITE / ENTITY PENETRATION
Pantera Venture Fund III LP — CONFIRMED CIK 0001732380 — CONFIRMED August 11, 2026 Form D/A — CONFIRMED $206.412931M cumulative sold — CONFIRMED 224 investors — CONFIRMED July 31, 2018 first sale — CONFIRMED Rule 506(c) — CONFIRMED Section 3(c)(7) — CONFIRMED Pantera Venture Fund III A LP — CONFIRMED CIK 0001751437 — CONFIRMED September 18, 2026 Form D/A — CONFIRMED $16.751356M cumulative sold — CONFIRMED 78 investors — CONFIRMED September 13, 2018 first sale — CONFIRMED Rule 506(c) — CONFIRMED Section 3(c)(1) — CONFIRMED Pantera Venture III GP LLC — CONFIRMED Pantera Capital Partners LP promoter / management relationship — CONFIRMED Pantera Capital Management LP adviser relationship — SEC ADV CONFIRMED Official $175M Fund III size — COMPANY REPORTED Official 32 Fund III investments — COMPANY REPORTED 2018 Fund III launch — COMPANY REPORTED Alchemy Fund III investment — COMPANY CONFIRMED Current Fund III portfolio — PARTIALLY PUBLIC Current Fund III NAV — NOT PUBLICLY DISCLOSED Current Fund III DPI — NOT PUBLICLY DISCLOSED Current Fund III TVPI — NOT PUBLICLY DISCLOSED Current Fund III IRR — NOT PUBLICLY DISCLOSED Current loss ratio — NOT PUBLICLY DISCLOSED Current fee schedule — REQUIRES FUND DOCUMENTS Current carried interest — REQUIRES FUND DOCUMENTS Current remaining unfunded commitments — REQUIRES FUND DOCUMENTS
WHY $175M AND $223M CAN BOTH APPEAR
PANTERA WEBSITE: Reports Fund III size of $175M MAIN FORM D: Reports $206.41M cumulative sold A FORM D: Reports $16.75M cumulative sold FORM D PURPOSE: Securities-offering disclosure WEBSITE FUND SIZE PURPOSE: Manager-level presentation of fund scale POTENTIAL DIFFERENCES: Parallel vehicles; historical subscriptions; fund accounting conventions; transfers; recycling; commitments versus sold interests CURRENT PUBLIC EVIDENCE: Insufficient to reconcile every dollar CORRECT APPROACH: Preserve both figures and clearly label their different sources INCORRECT APPROACH: Claim Pantera's website is wrong or declare $223.16M current AUM without partnership-level evidence
CORE INVESTOR QUESTIONS
Why does Pantera report official Fund III size of $175 million while the main Form D reports $206.41 million cumulatively sold What explains the additional $16.75 million Fund III A vehicle Are Fund III LP and Fund III A LP parallel investors in the same portfolio Do both vehicles hold identical investments Why does one rely on Section 3(c)(7) and the other on Section 3(c)(1) Do the vehicles have different investor eligibility requirements Do they have identical management fees Do they have identical carried interest Do they have identical expense allocations What is current NAV of the main Fund III LP What is current NAV of Fund III A What is current combined economic NAV What percentage of committed capital has been distributed What is current DPI What is current RVPI What is current TVPI What is gross IRR What is net IRR What is the current unrealized portfolio How many of the original 32 investments remain active How many investments have been fully realized How many investments have been partially realized How many investments have been written to zero How many are marked below cost How much of current NAV is represented by the five largest companies What is Alchemy's current contribution to NAV Which holdings are currently publicly traded Which holdings have completed secondary sales Which companies were affected by the 2022 crypto downturn Which companies required bridge financing What follow-on reserves remain Can Fund III make new investments in 2026 Can it only make follow-on investments Have investment-period extensions been approved When does the partnership terminate How many extension periods remain Can the GP sell positions through secondary transactions How are token distributions from portfolio companies treated Can portfolio companies issue tokens directly to the fund Are token rights held by Fund III or another Pantera vehicle How are illiquid token warrants valued How are private-company marks determined Are third-party valuation providers used Who is the current auditor Who is the current administrator What annual financial statements are provided to LPs What is the management fee after the investment period What carried interest applies Is carried interest calculated deal-by-deal or at the fund level What clawback provisions apply What key-person provisions apply to Daniel Morehead and the venture team How are opportunities allocated between Fund III, Blockchain Fund IV, Fund V and other Pantera vehicles
CORE RISKS
Blockchain venture risk; early-stage company failure; private-company valuation uncertainty; crypto-sector cyclicality; regulatory risk; token classification risk; exchange and custody infrastructure risk; smart-contract ecosystem risk; technology obsolescence; competition; follow-on financing risk; down-round dilution; long holding periods; IPO-market risk; M&A exit risk; secondary-market discounts; concentration in a small number of winners; key-person dependence; valuation marks may differ substantially from realized proceeds; portfolio companies may issue volatile tokens; related Pantera vehicles can create allocation conflicts; private securities are illiquid; cumulative Form D sales do not equal NAV; $175M manager-reported fund size does not equal $206.4M cumulative Form D sales; arithmetic combination of the two Form D vehicles does not establish $223.16M current fund assets.
PRIMARY EVIDENCE REVIEWED
U.S. SECURITIES AND EXCHANGE COMMISSION Pantera Venture Fund III LP CIK 0001732380 Form D/A August 11, 2026
U.S. SECURITIES AND EXCHANGE COMMISSION Pantera Venture Fund III A LP CIK 0001751437 Form D/A September 18, 2026
U.S. SECURITIES AND EXCHANGE COMMISSION Pantera Venture Fund III LP Historical Form D filings 2018-2026
SEC INVESTMENT ADVISER PUBLIC DISCLOSURE Pantera Capital Management LP Pantera Venture Fund III LP Private Fund ID 805-8320850481 Pantera Venture III GP LLC
PANTERA CAPITAL OFFICIAL WEBSITE Pantera Venture Venture Fund I Venture Fund II Venture Fund III Blockchain Fund IV Firm history Venture realization statistics
PANTERA BLOCKCHAIN LETTERS Alchemy Series A Venture Fund III investment confirmation Historical portfolio-company programming Fund III LP investor-call evidence
IMPORTANT FORM D NOTICE
Form D is a notice of an exempt securities offering.
It does not mean that the SEC has approved Pantera Venture Fund III, Pantera Capital, Daniel Morehead, Alchemy, blockchain technology or any valuation applied to a portfolio company.
The main Fund III vehicle currently reports $206,412,931 cumulatively sold.
The Fund III A vehicle currently reports $16,751,356 cumulatively sold.
Pantera separately describes Venture Fund III as a $175 million fund.
These figures should be preserved as separate disclosure metrics rather than forced into one unsupported AUM number.
INDEPENDENT ASSESSMENT
Pantera Venture Fund III has one of the strongest identity and strategy evidence chains among crypto-focused private funds.
The fund has operated continuously since 2018.
Its General Partner is directly identified.
Its adviser relationship appears in SEC adviser records.
Pantera publicly discloses the fund's vintage, strategy, official $175 million size and 32-investment portfolio count.
And Pantera has specifically confirmed at least one major Fund III investment in Alchemy.
The more interesting research issue is the capital structure.
The main vehicle now reports $206.41 million cumulatively sold, while Fund III A reports another $16.75 million.
Those figures exceed Pantera's publicly stated $175 million fund size if simply added together.
That is precisely why FilingDossier should not use Form D cumulative sales as a substitute for fund NAV or official committed capital.
The current public record does not provide enough information to reconcile the entire difference.
The investment analysis has also changed with time.
In 2018 the central question was whether institutional blockchain infrastructure would develop.
By 2026, the central question is how Fund III converted early private investments into realized cash, what value remains in its private portfolio and how much of its performance depends on a small number of highly successful companies.
For an eight-year-old venture vintage, DPI, TVPI, RVPI, net IRR, write-offs and remaining portfolio concentration are now more informative than the original fundraising total.
The SEC record verifies the fund and its parallel structure.
Pantera's website verifies the strategy and historical operating platform.
Neither source, by itself, establishes Fund III's current NAV or final investment return.