Cameron and Tyler Winklevoss are making a high-profile bet on privacy coins, filing with U.S. regulators to launch a spot Zcash exchange-traded fund as the once-shunned asset enjoys a dramatic revival. If approved, the product would join a fast-growing lineup of Zcash-focused funds.

The Winklevoss Zcash ETF, outlined in an S-1 registration statement filed Monday with the Securities and Exchange Commission, would hold ZEC directly and seek to track its price, giving investors exposure through a traditional brokerage account rather than requiring them to buy and store the tokens themselves. The ETF wrapper is the structure financial advisors and retirement platforms typically rely on to gain exposure to assets they cannot hold directly. The fund is slated to trade on Nasdaq under the ticker "WINK" and would carry a 0.25% sponsor fee.

Gemini, the twins' crypto exchange, would serve as custodian, holding the trust's ZEC in cold storage. Winklevoss Capital Fund has indicated an interest in purchasing up to $100 million of shares in the offering, though the filing notes that the commitment is non-binding.

The trust has also tapped Cypherpunk Technologies, the Winklevoss-backed Zcash treasury company, to serve as its "Zcash Ecosystem Partner," advising on protocol matters and coinholder voting.

The filing lands amid a striking resurgence for Zcash, a privacy coin that lets users shield the sender, recipient, and amount of a transaction using a branch of cryptography known as zk-SNARKs. That privacy has long made such assets a flashpoint with regulators and exchanges, several of which delisted privacy coins in recent years. After years as a regulatory pariah, ZEC has surged into the top ranks of digital assets this year, driven by rising concern over financial surveillance and a wave of institutional packaging.

Crypto asset manager Grayscale converted its Zcash Trust into a spot ETF in August and later moved to split its shares, while 21Shares listed Europe's first Zcash exchange-traded product. A WINK listing would add the industry's most recognizable set of twins to that push.

The S-1 does not shy away from the risks, flagging ZEC's extreme volatility and the unique vulnerabilities that come with privacy coins. It specifically notes the soundness bug discovered this year in Zcash's Orchard shielded pool, which briefly sent ZEC down roughly 50% before the network patched the flaw with the Ironwood upgrade.

The filing is only a first step, and the SEC must still sign off before trading can begin; spot crypto launches generally require both an effective registration statement and an approved exchange listing rule, a review process that has often involved rounds of regulatory feedback and amendments. Like all spot crypto ETFs, the fund would track a highly volatile asset, meaning investors could lose big or win big on a coin that has surged more than 2,000% over the last year.