Tytan is a non-reporting company and he's not a controller per 144. You can sell unregistered shares into the market if you meet just 1 of many exceptions. I didn't even think it was possible to sell unregistered shares into the market until I asked my Securities professor about it 2 weeks ago and he said it happens all the time. This could be one of those times.
If they're restricted, Leonard just has to give permission to the TA to remove the legend and sell the shares. Hence the reason Leonard was able to tell us that the seller was a holder of the "old company". It's not up to the TA to determine if the seller meets an exception. If it was, then they would be an underwriter and/or broker-dealer and get sued by the SEC all the time for an illegal act by one of their clients even if they were lied to.
This guy could be doing it illegally out of desperation. This we don't know but it does happen a lot and desperation is usually the first element to corporate crimes. Heavan's Angel said this guy was a broker so he would certainly have the means/knowledge to liquidate ASAP if needs be. AIMO