Yes its possible you might gain a few new moles I did but to be honest they never worried me they are very small and blend in well once you have got a nice tan I have two small ones I either side of my cheek not much bigger then a pin head
Everyone is individual, it's near impossible to predict how all pigmentation will react to a-MSH &/or photo-therapy. In my experience, some moles temporarily darkened & some lightened/blended in.... Overall, my beauty marks(/sun damage) evolved naturally throughout my usage and never took away from the cosmetic benefit dark melanin provided my skin.
got a few tiny black ones when first started MT2 but they faded after the first season , old moles did grow a bit darker but they also tended to blend with time.