One has to become familiar with the IRS Whistle Blower statures.
One can make money in trading OTC stocks, in promoting OTC stocks, in shorting OTC stocks. One can also make money by collecting rewards, from the IRS for reporting suspected avoidance of taxes. One does not have to have any relationship with the tax filer, share holder, or company to report suspected IRS tax avoidance.
It is more difficult to report and collect on SEC Whistle Blower statures however.
So the suggestion is made...report your income for Certs and Shares issued for services rendered. Report income for management's personal use of company's funds, report income for company's payment of management's personal expenses and travel.
IMO, the statement/quote that one must have a relationship with the company is completely false.
My suggestion, take the stock capital loss this year if one can. Report all income from Certs, Services provided, and management's questionable expenses paid by Company. Review any transfers of funds to foreign bank accounts for compliance. Also file amended claims from prior years for questionable issues. Avoidance of interest and penalties can be more important than the initial taxes due.