OTC can be fulfilled via transfer of ownership of cold wallets.

(Over-the-Counter) trade in the cryptocurrency market can involve the transfer of ownership of a cold wallet. This method is a more direct and private way of transferring large amounts of Bitcoin or other cryptocurrencies between parties. Using this method could violate regulations such as Anti Money Laundering and Know Your Customer but were talking about large institutions here that have legal teams to make sure these regulations requirements are met. due to the SEC current regulations, this is a valid method of obtaining crypto OTC. let me know your thoughts! I'm interested in what ya'll think!