Winklevoss Zcash ETF (WINK): SEC Filing, Fees, Approval Status & Launch Date

A new Delaware trust called the Winklevoss Zcash ETF filed a registration statement with the U.S. Securities and Exchange Commission on October 6, 2026. The sponsor is Winklevoss Asset Services, LLC, and the fund would hold only ZEC, charge 0.25 percent a year and list on Nasdaq under the proposed ticker WINK. That is the whole of what is established. The registration statement has not been declared effective, the shares are not listed, and the filing leaves blank the seed investor, the pricing benchmark, several service providers and the basket size, and gives no launch date. This guide separates what the SEC document says from what the media have added, and explains how WINK differs from the Zcash investment products that already trade.

What exactly was filed on October 6, 2026?

You can read the document yourself on EDGAR. The trust was formed on the day it filed and its sponsor five days earlier, so it has no operating history, and the document is plainly an early draft: well over a hundred fields are blank placeholders, and many more passages sit in square brackets. That matters for how much weight any single number deserves.

Key facts: confirmed, proposed and unknown

How the proposed ETF would work

The trust's only purpose would be to hold ZEC. The shares would represent fractional ownership of the trust and trade on Nasdaq like any other listed security, so investors could buy and sell them through a normal brokerage account.

Supply would be managed by authorized participants, large financial firms that deliver ZEC or cash to the trust in exchange for blocks of new shares ("baskets"), or hand shares back for redemption. The filing allows both the in-kind route, in which ZEC itself is delivered, and a cash route, and its own risk section notes that a cash model involves more operational steps and execution risk than in-kind. The basket size is blank, and no authorized participant is named; the filing mentions only an unnamed initial authorized participant.

The trust's net asset value would be set each day at 4:00 p.m. New York time by reference to a "Pricing Benchmark", an aggregate of trading on major ZEC platforms. The benchmark provider and the underlying index are still blank in the filing, so how WINK would price itself is not yet known.

Fees, custody and ZEC backing

Fee. The proposed sponsor fee is 0.25 percent of ZEC holdings a year, accruing daily and payable monthly in ZEC or cash. It is a "unified" fee: the sponsor says it would pay ordinary expenses such as service providers, listing, audit and legal costs out of it, with extraordinary expenses carved out. The sponsor may waive some or all of the fee for periods it chooses, but the filing sets no waiver and no cap. For comparison, Grayscale's ZCSH charges 2.5 percent, ten times as much; see the ZCSH guide.

Custody. Gemini Trust Company, LLC would hold all of the trust's ZEC. It is a custody provider supervised by the New York State Department of Financial Services and an affiliate of the sponsor, which the filing names as a risk: the custody agreement "was not negotiated at arm's length", so its terms may be less favorable to the trust than an unaffiliated custodian would have given. The filing says ZEC would sit in cold storage at segregated addresses "directly verifiable via the Zcash Blockchain". It also describes a separate clearing account used for settlement, in a passage that is still in brackets, where ZEC may be held in omnibus hot wallets.

Backing. Each share would be a fractional interest in ZEC held by the custodian, and the filing says the trust "will only invest in ZEC". That is a description of the intended structure, not a guarantee of how the shares will trade relative to the value of their ZEC. Premiums and discounts are possible in any exchange-traded product.

Who is behind it: Winklevoss, Gemini and Cypherpunk

What the filing documents: the sponsor, Winklevoss Asset Services, LLC, is wholly owned by Winklevoss Asset Services Holdings, LLC, and the cover page lists Cameron Winklevoss as its contact. Its custodian, Gemini Trust Company, is an affiliate. The trust has also entered an agreement under which Cypherpunk Technologies Inc. would serve as its "Zcash Ecosystem Partner", providing services that may include help with coinholder polling and voting, guidance on protocol developments and other advice on Zcash matters.

What is documented elsewhere. Cypherpunk Technologies is the Nasdaq-listed company, formerly Leap Therapeutics, that adopted a ZEC treasury strategy after a 58.88 million dollar private placement led by Winklevoss Capital. A Cypherpunk press release filed with the SEC in November 2025 also says that Will McEvoy, a principal at Winklevoss Capital, serves on its board and as its Chief Investment Officer. The Winklevoss twins have also been reported by DL News to have donated about 1.2 million dollars in ZEC to Shielded Labs in January 2026. Zooko Wilcox, profiled in our article on him, has been a strategic advisor to Cypherpunk since December 2025 according to the company's press release. The S-1 does not mention him.

None of this is hidden or improper, but it describes a structure where sponsor, custodian and ecosystem partner sit in one network. The filing itself flags the affiliated custodian as a risk, and readers can weigh it for themselves.

The 100 million dollar figure. The filing says that Winklevoss Capital Fund, LLC, through one or more affiliates, "has indicated an interest in purchasing an aggregate of up to $100 million of Shares" from authorized participants or in the market, and states that these indications "are not binding agreements or commitments". So it is a non-binding expression of interest to buy shares after launch. It is not seed capital, because the seed investor and amount are blank, and it is not a committed investment. Some outlets have called it a seed commitment, which is looser than the document's own wording.

SEC approval: where this stands and what to watch

A Form S-1 is a registration statement. The SEC staff reviews it, the sponsor answers with amendments, and the cover of this one is explicit that the shares may not be sold until the registration statement is effective. Effectiveness means the SEC has allowed the offering to proceed, not that it endorses the product, which is why saying "the SEC approved this ETF" is inaccurate even when a product does launch.

Separately, the shares need an exchange listing. How crypto trusts get listed changed in September 2025, when the SEC approved generic listing standards for commodity-based trust shares, as summarized by Goodwin and in a Congressional Research Service note. Whether WINK would qualify, or need a product-specific rule filing, is not addressed in the S-1, which does not mention either route. For that reason this page states no deadline.

What realistically has to happen, in no fixed order and on no published timetable:

1. Amendments. An S-1/A that fills in the blanks, including the seed investor, benchmark, administrator, basket size and the exhibits.
2. Listing. Nasdaq's listing process, and a listing notice.
3. Effectiveness. The registration statement declared effective.
4. First trade. The shares begin trading under their ticker, if the product proceeds.

Each step is public: new documents appear on the trust's EDGAR page, and the ticker only becomes real when the exchange issues a listing notice.

WINK compared with ZCSH and other Zcash investment products

These are different product types, and the differences matter more than the headline fee:

Grayscale describes ZCSH as the first U.S. exchange-traded product to offer spot exposure to ZEC, and The Block reported on October 6 that it remains the only one trading. WINK would be a second US spot product if it launched, but it is not one today. Our full guides cover each existing product: the ZCSH guide for the US fund, the 21Shares guide and the Valour guide for the European ETPs, and the income ETF explainer for the options-based fund. Press also reported in December 2025 that Bitwise filed for a Zcash strategy ETF as one of eleven such products; we have not verified its current status. Our ZCSH flow tracker covers ZCSH only; there is no WINK data until a WINK product trades.

What a launch could mean: scenarios, not predictions

A filing alone moves nothing, and these are scenarios rather than forecasts:

• It launches and gathers assets. A far lower fee than ZCSH could pull some investors away from it, or pressure its fee. But fees are one factor among several: liquidity, brand, custodian, creation mechanics and how closely each product tracks ZEC all matter.
• It launches small. A new fund can take a long time to build liquidity, and a thinly traded fund can trade at a premium or discount.
• It is delayed, changed or withdrawn. Preliminary filings are routinely amended, and some products never launch.

In every case, demand for fund shares ultimately means creation baskets and so purchases or deliveries of ZEC, which is why analysts watch fund flows. We track that for ZCSH on the flow tracker, where daily settled flows are reported with a delay.

Privacy: owning ETF shares is not owning private ZEC

Zcash's defining feature is shielded transactions, and a fund share has none of it. If you buy a spot Zcash ETF in a brokerage account you hold a security, not coins: no private keys, no ability to withdraw, send or receive ZEC, no shielded balance, and a brokerage record tied to your identity. To use ZEC privately you need to hold it yourself in a wallet and learn how shielded and transparent addresses differ; our privacy page and guide to buying ZEC cover the practical side.

The same question applies to the fund's own holdings. The filing says only that the trust's ZEC would sit at cold-storage addresses that are "directly verifiable via the Zcash Blockchain". It does not say whether they are shielded or transparent. Our reading is that a balance anyone can verify on the chain implies publicly visible addresses, since a shielded pool balance cannot be checked without a viewing key, but the document does not say so and we do not present it as fact. The filing's risk factors also discuss legal and regulatory pressure on privacy-focused assets.

Risks and limitations

• It is a draft. The prospectus is preliminary and incomplete. Several figures about Zcash, including price and pool statistics, are still bracketed placeholders and should not be quoted as final.
• No approval and no date. Effectiveness, a listing and a first trade are all still ahead, and any of them could fail or change.
• Related-party structure. The sponsor, custodian and ecosystem partner are linked, and the filing itself flags the custodian relationship.
• Zcash-specific risks that the filing discloses. These include a soundness vulnerability in the Orchard shielded protocol found in late May 2026 and fixed in early June, with no evidence it was exploited but no way to rule it out conclusively; the Ironwood upgrade of July 28, 2026, covered in our Ironwood article; the risk that quantum computers could weaken today's cryptography; and legal risk for privacy coins.
• Delisting. The trust would terminate if its shares were delisted and not approved on another exchange within five business days.
• Fewer protections. The trust is not registered under the Investment Company Act of 1940, so investors do not receive that law's protections.
• Tax. The intended grantor-trust treatment rests on a counsel opinion that the filing itself describes as not free from doubt.
• Volatility. ZEC can fall as quickly as it can rise, and nothing here suggests any return.

What to monitor

1. A new document on EDGAR. An S-1/A would show whether blanks such as the seed investor, benchmark and administrator are filled in, and whether the fee changes.
2. An exchange listing notice. Only Nasdaq's notice makes WINK a real ticker.
3. Fee waiver terms. The filing permits waivers but sets none.
4. Custody details. Whether the filing, once amended, says what kind of addresses hold the ZEC.
5. Competing filings. Other issuers' Zcash products change the picture.

We update this page when any of those happen. The status box at the top and the key-facts table are the parts that will change; the explanations below them should stay valid.

Sources and methodology

Facts about the filing come from the S-1 itself, read in full on EDGAR on October 6, 2026. Anything not in the document is attributed to a named source, and where we could not verify something we say so. Press coverage was used to cross-check, not as a foundation.

Primary sources

• The S-1 prospectus: sec.gov
• The filing index (accession number 0001104659-26-113940): sec.gov
• The trust's EDGAR record (CIK 0002158471): data.sec.gov
• Cypherpunk Technologies' 8-K exhibit on its private placement: sec.gov
• Cypherpunk's announcement of Zooko Wilcox as strategic advisor, December 9, 2025: prnewswire.com
• 21Shares Zcash ETP product page: 21shares.com
• Valour Zcash ETP launch release, September 29, 2026: globenewswire.com

Press and legal commentary

• The Block, "Winklevoss group seeks to launch Zcash ETF with 0.25% fee, proposed WINK ticker", October 6, 2026: theblock.co
• Decrypt, October 6, 2026: decrypt.co
• crypto.news, October 6, 2026: crypto.news
• DL News on the Winklevoss donation to Shielded Labs, January 21, 2026: dlnews.com
• Goodwin on the SEC's generic listing standards: goodwinlaw.com
• Congressional Research Service, "Crypto and commodity-based ETPs": congress.gov
• CoinDesk on Bitwise's strategy ETF filings, December 31, 2025: coindesk.com

Known gaps. The filing is preliminary and many fields are blank or bracketed; the Zcash statistics inside it are not quoted here for that reason. We found no press release or statement from the sponsor about the filing. We could not confirm on what basis ZCSH was listed or how WINK would be listed, and we have not verified the status of Bitwise's product. Product facts for ZCSH, 21Shares and Valour are covered, with their own sources, in our linked guides.

This article explains a proposed product and is not investment, legal or tax advice. ZecZcash is an independent Zcash community site and is not affiliated with Winklevoss Asset Services, Gemini, Cypherpunk Technologies, Grayscale, 21Shares, Valour, Nasdaq or any other issuer mentioned. Read the final prospectus before buying any fund.