Rhine, no matter if a broker is offshore or not, they all have to trade through US regulated firms. No if, and or buts.
A slight correction to your comment. What RCCH needs to determine if there are more shares o/s than authorized is the NOBO, OBO and T/A register listing cert holders, if any.
That is funniest thing about OTC companies claiming NSS, all they need to do is order the three, which can received within a week's time at most and a couple of grand to do.
If there is a significant amount of unauthorized shares o/s, then the Company can contact Finra and "blue sheet" the ticker, which will list every trade by broker and on whose behalf the broker traded. The T/A and Finra will then easily discover where the unauthorized shares came from.
Then they turn to the SEC & DOJ and take action.