OTM is not considered an expanding projectile, as it fragments in a similar fashion as FMJ like M193 and M855.
DOD JAG has clearly articulated that new ammo needs to be requested using appropriate requirements (ex. penetration no less than 12" and no more than 18") and NOT asking for increased "lethality" or for expanding bullets.
The mk318 isn't OTM is it? Maybe....but 70gr tsx isnt.