Cameron and Tyler Winklevoss filed an S-1 registration statement with the U.S. Securities and Exchange Commission on Monday for a spot Zcash exchange-traded fund that would hold ZEC directly and trade on Nasdaq under the ticker "WINK."

The fund would charge a 0.25% sponsor fee. Gemini, the Winklevoss-owned crypto exchange, would serve as custodian and hold the trust's ZEC in cold storage.

Winklevoss Capital Fund has indicated non-binding interest in purchasing up to $100 million of shares at launch, according to the filing. Cypherpunk Technologies, a Winklevoss-backed Zcash treasury company, would act as "Zcash Ecosystem Partner" and advise on protocol matters and coinholder voting.

What does the filing add to an existing Zcash product slate?

The S-1 lands less than three months after Grayscale converted its Zcash Trust into a spot ETF in August and later moved to split its shares. The 21Shares Zcash ETP, Europe's first such product, listed in the same window.

A WINK listing would attach the Winklevoss brand, synonymous with the earliest U.S. crypto ETF campaign via Gemini's Bitcoin filing a decade ago, to a privacy-focused asset long absent from U.S. regulated wrappers. The proposed ticker nods to the founders' surname and the Gemini lineage.

ZEC has rallied more than 2,000% over the past year, according to market data, lifting it into the upper tier of digital assets by capitalization. The move has tracked renewed attention to on-chain financial privacy and a wave of institutional packaging that has pulled shielded assets into traditional brokerage channels.

Why is the S-1 notable on regulatory grounds?

Zcash has sat on the margins of U.S. crypto policy because its shielded-pool design obscures the sender, recipient and amount of a transaction through zero-knowledge proofs called zk-SNARKs, complicating anti-money-laundering oversight.

The prospectus flags operational and compliance risks other spot crypto ETF filings have not confronted in the same terms. It cites the soundness bug discovered this year in Zcash's Orchard shielded pool, which briefly sent ZEC down roughly 50% before developers patched the network with the Ironwood upgrade.

That disclosure treats shielded-pool integrity as a material risk to fund operations, a framing that may set a template for future privacy-coin filings and force underwriters and the SEC to formalize how shielded assets are audited and reported.

How does WINK compare with existing Zcash products?

Key structural terms in the S-1:

• Direct ZEC holding under Gemini cold-storage custody
• 0.25% sponsor fee, in line with spot Bitcoin and Ether products
• Winklevoss Capital Fund as a non-binding anchor with up to $100 million in interest
• Cypherpunk Technologies providing ecosystem and governance input
• Listing venue: Nasdaq under the proposed symbol "WINK"

Grayscale's spot Zcash ETF launched via trust conversion with a longer fee history and a different cost structure. The 21Shares ETP operates under European market-abuse and disclosure regimes. A WINK approval would extend the U.S. spot wrapper framework to a privacy coin for the first time.

What comes next?

The SEC must approve the registration statement, including any applicable exchange rule changes, before trading can begin.

Approval timing for spot crypto ETFs has compressed since the first Bitcoin products launched in early 2024, with Ether, Solana and XRP wrappers following in subsequent cycles. The Winklevoss filing now tests whether the agency will extend that pipeline to a shielded-pool asset with a documented soundness incident on its record.