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Winklevoss files S-1 for spot Zcash ETF WINK on Nasdaq, 0.25% fee

Winklevoss Asset Services filed an S-1 October 6 for a spot ZEC ETF listing on Nasdaq under ticker WINK, Gemini as custodian, with Winklevoss Capital Fund signaling up to $100M in seed interest.

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Winklevoss Asset Services filed a preliminary Form S-1 with the SEC on October 6, 2026 for a spot Zcash (ZEC) ETF under proposed ticker WINK, with The Block and Decrypt both carrying the filing details. The fund would list on Nasdaq, charge a 0.25% annual sponsor fee, and use Gemini Trust Company as custodian.

What was filed

Per the two reports, the registration statement discloses:

  • Issuer: Winklevoss Asset Services, a newly formed sponsor wholly owned by Winklevoss Asset Services Holdings.
  • Form: S-1 preliminary registration (the retail-fund track; the 19b-4 exchange rule change filing from Nasdaq follows separately).
  • Ticker: WINK on Nasdaq.
  • Fee: 0.25% annual sponsor fee.
  • Custodian: Gemini Trust Company (the Winklevoss-owned New York trust-chartered custodian).
  • Underlying: direct spot ZEC holdings.
  • Ecosystem partner: Cypherpunk Technologies, named in the filing as a "Zcash ecosystem partner" responsible for protocol advisory and coinholder polling.
  • Seed interest: Winklevoss Capital Fund disclosed a non-binding indication of interest in buying up to $100 million of shares at launch.

Neither write-up names the index, authorized participants, or an index provider.

Where it sits in the Zcash-ETF queue

WINK is the latest filing in a Zcash-ETF wave that opened in August 2026, per Decrypt's recap:

  • Grayscale converted its existing Zcash Trust into a spot ETF (ZCSH) in August 2026.
  • 21Shares listed a European Zcash ETP in parallel.
  • Winklevoss Asset Services is now the second US spot ETF filer and the first to pair a 0.25% fee tier with a vertically integrated custodian stack (Gemini + Winklevoss Capital).

The 0.25% fee undercuts Grayscale's trust-conversion products, which historically launch at 1.5–2.0% before dropping. Winklevoss is also the only filer whose sponsor, custodian and anchor investor all sit inside the same group.

Approval mechanics

An S-1 alone does not clear the ETF for trading. Two parallel paths run from here:

  1. S-1 effectiveness — the SEC's Division of Corporation Finance reviews disclosure (fund mechanics, risks, custody arrangements). Comment letters are expected.
  2. 19b-4 rule change — Nasdaq must file to list the shares; the SEC's Division of Trading and Markets has up to 240 days to approve or disapprove under Section 19(b)(2).

Only when both clear can WINK trade. The parallel Zcash ETFs already in queue mean the SEC's answer on one effectively sets the answer on the others — a template approach the agency used for the January 2024 spot Bitcoin ETF approvals and the May 2024 Ethereum approvals.

Attribution hedge

Both reports describe filing details only. No order of magnitude for assets under management, no launch date, and no mention of Zcash protocol features (shielded vs transparent-pool handling) that the fund will or won't support have been disclosed in the summaries available. The S-1 itself on EDGAR will carry those once posted.

What to watch

  1. The S-1 on EDGAR — official filing text, authorized participants list, redemption/creation mechanism (in-kind vs cash), and whether the fund takes exposure to shielded ZEC.
  2. Nasdaq's 19b-4 — the exchange rule change filing is the gating event for an approval timeline.
  3. Competing Zcash ETF fee compression — Grayscale ZCSH, 21Shares, and whichever filer follows WINK will reprice against 0.25%.
  4. Treasury / FinCEN posture on privacy-coin ETFs. Zcash's selective-disclosure mechanics make the custodian stack and the AML wrapper material — any US regulator view on shielded-pool exposure in a registered fund will set precedent for Monero filings that follow.

Context

Spot ETF filings for privacy coins are the frontier case for the post-GENIUS Act approval regime: the regulatory question isn't whether ETFs for new crypto assets can clear (that's settled since January 2024), but whether assets with mandatory or optional privacy features clear under the same disclosure standards as transparent-ledger assets. The Winklevoss filing — same bench, same custody arrangement, same ticker family as their earlier Bitcoin ETF (never approved; became Gemini's custody line of business instead) — is the test case for that question on a US exchange.

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