The Form 211 no longer requires SEC/FINRA approval. It can be processed and approved by OTC Markets. There's no requirement to wait out any statute of limitations.
The new rules bring OTC stocks more in line with stocks on major exchanges which can resume trading immediately after their 10 day halt.
The link you cited does not apply here. It concerns the SEC's statute of limitations on enforcing "disgorgement actions". From all indications, the SEC halted COUV because of false or misleading claims from the Covid mask company that they had purchased and subsequently sold after the halt. No one at COUV made any unjust profit, which is what disgorgement actions seek to reverse. In any event, there's no requirement related to any statute of limitations. The broker dealer or OTC markets must satisfy themselves via due diligence and supplemental information requirements that the company is no longer subject to further suspension actions. As far as I can tell, how they do so is not defined.