“Moreover, discovery has revealed that BHL can at least effect transfers of BAM’s crypto assets from customer deposit wallets to hot wallets when transfers get ‘stuck’ while using the PNK system. BAM’s Head of Clearing, Tao Zhang, testified that he routinely reaches out to a chat group involving BHL employees that he calls the ‘BHL wallet team’ when BAM’s clearing team has ‘technical issues’ with respect to asset movement,” the filing said.