This is another interesting "disciplinary action" from Nadex. The full details are in the attached PDF from the Nadex website. Here's a summary of the case. Nadex says Julio Salgado Velez transferred $100,000 into his Nadex account. He started trading using the funds. In so doing he violated Rule 5.19(g)(1) which says:
Now I think this is interesting. They claim he violated a rule which prohibits trading on behalf of someone other than yourself. How do they know he wasn't trading on his own behalf. The answer is found in this from the report:
In its investigation as to t he source of these funds, Nadex discovered Velez had received a $101,000 .00 transfer on May 14, 2018 from an investment fund , Capstone Currency, LLC, owned and operated by another Nadex Member . Immediately following this transfer of funds, Velez moved $100,000 .00 to his business account, then to his personal account, before finally depositing with Nadex.
So, to find out where the $100,000 in his Nadex account came from, they obtained his bank records and tracked the funds from his business bank account to his personal bank account to his Nadex account. That is very broad reach. Velez didn't cooperate with Nadex in the investigation. Nadex concluded that the $100,000 was money Velez traded on behalf of Capstone Currency, LLC rather than on his own behalf. So, he broke the rule saying you can't trade for someone other than yourself.
I think it is interesting that they go to such lengths to make sure those trading on Nadex are following the exchange rules.