The article by Liu Lei's lawyer team pointed out that two OTC situations may constitute the crime of illegal business operation. One is if the case-handling unit interprets OTC as "making payment settlements for the platform", then engaging in OTC may constitute the crime of illegal business operation, such as the typical money laundering through underground banks. In addition, if OTC merchants continue to buy low and sell high at a high frequency to earn the difference, and they also know that what they are doing is helping overseas banks to exchange foreign currency, then OTC merchants may constitute accomplices to the crime of illegal business operation.