I just scanned two quarterly reports, which are the only kind of filings I see for the past couple of years on OTCMarkets, and no where did I see anything about insider holdings, or large shareholders, or any information whatsoever about the share structure, other than it appears they paid for a lot of services with shares - but nowhere is there any mention that any of these shares are restricted.
That really doesn't surprise me, about what I would expect.