Yes, on the OTC much of the activity is "in the know ". Seems totally unregulated. And now TNEN is on the way back from that low you mention. An announcement could be coming any day.
Week 46 Wrap: Copper hits 2mth low as Trump threatens net zero pace; US rally fades; HotCopper’s picks
AN1 CuFe sells its Crossroads gold royalty to Northern Star for $4M cash; says better than waiting for mine launch