Winklevoss Asset Services has filed for a spot Zcash exchange-traded fund that would trade under the ticker WINK. The proposed fund carries a 0.25% fee and would use Gemini as its custodian. If approved, it would go head-to-head with Grayscale's Zcash Trust, which trades under ZCSH.
A direct challenge to Grayscale's Zcash Trust
Grayscale already runs a Zcash product, the Zcash Trust. But that's a trust, not an ETF, and it trades over the counter under ZCSH. The Winklevoss filing, if it clears regulatory hurdles, would offer a competing spot ETF wrapper — one with a disclosed 0.25% fee and a custodian arrangement that's already familiar to crypto-native investors. Grayscale hasn't commented on the new filing, and there's no word yet on whether it plans to convert its own trust into an ETF. For now, the two products would sit in different regulatory buckets, but they'd chase the same pool of investors who want Zcash exposure without holding the underlying asset directly.
Why Gemini's custodian role matters
Gemini, the crypto exchange founded by Cameron and Tyler Winklevoss, would serve as custodian for the proposed ETF. That's a notable detail. Custody is one of the biggest sticking points for regulators evaluating crypto ETFs — they want to know who holds the keys, how those keys are secured, and what happens if something goes wrong. Gemini already provides custody services for other digital asset products, and its involvement here keeps the operation inside the Winklevoss ecosystem. The filing doesn't say whether Gemini would hold Zcash in cold storage, use a qualified sub-custodian, or both. Those are the kind of operational specifics that tend to emerge later in the review process, usually in amended filings or responses to SEC staff comments.
The 0.25% fee puts pressure on competitors
At 0.25%, the proposed fee is aggressive for a spot crypto ETF. Grayscale's Zcash Trust carries a higher expense ratio — typical for trust structures, which often charge 2% or more annually. The Winklevoss filing doesn't mention a fee waiver or promotional rate, just the flat 0.25%. That number matters because it sets a benchmark. If the WINK ETF launches at that price, Grayscale would face a choice: cut its own fees, convert ZCSH into an ETF with a lower expense ratio, or cede the cost-conscious segment of the market. No timeline has been given for when the SEC might rule on the WINK application. The agency hasn't published the filing on its public docket yet, and there's no indication of when the 19b-4 — the formal rule change proposal that would allow the ETF to list — will appear in the Federal Register.
Zcash's regulatory baggage
Zcash has a complicated history with regulators. The cryptocurrency uses zero-knowledge proofs to shield transaction details, which makes it more private than Bitcoin or Ethereum. That privacy feature has drawn scrutiny in the past, though Zcash also offers transparent transactions that are fully auditable. The filing comes at a time when the SEC has approved spot Bitcoin ETFs and is weighing spot Ethereum ETFs, but privacy coins remain a harder sell. No privacy-coin ETF has ever been approved in the U.S. The Winklevoss filing is the first serious attempt to change that. Whether the SEC treats Zcash differently from Bitcoin — because of its optional privacy — is the central question the review will have to answer.
What happens next
The filing is just the first step. Winklevoss Asset Services will need to file a 19b-4 with the SEC, which triggers a formal review period. The agency can approve, deny, or delay the proposal, and delays are common. Grayscale's own Zcash Trust has been trading since 2018, so there's an established market for the asset. But the ETF structure is new territory for privacy coins, and the SEC's stance on Zcash specifically hasn't been tested in a rule-change proceeding before. The next concrete marker will be the publication of the 19b-4 in the Federal Register, which starts the clock on the SEC's decision timeline. Until that happens, the WINK ETF exists only on paper.
