Unfortunately the sec is overwhelmed, although they do now and have had for a couple years, a " micro fraud unit". But, the general rule is to suspend , and possibly file suit against the orchestrators , criminal charges must be filed by the sec getting the DOJ involved, and that rarely if ever happens in Otc world. It would be appropriate to just suspend any symbol not current w a string of unsupported prs to elicit liquidity, but the sec knows that in many of those cases the SH are the ones penalized the most. But, if something is egregious and stands out , they have no truck w suspension, and there is no due process in those , it's a unilateral decision and appeals rarely are successful. Mainly because the appellants usually have much exposure and are smart enough to not open the can of worms further.