Is TradeSports trading on its own exchange?

I'm looking at the Iraq elections futures on TradeSports and notice that there have been a number of trades at 99.9. This is very strange to me because the trading fees are $0.04 per block per trade/expiry. So that means that any buy order at 99.2 or above would necessarily incur a loss because of trading fees. It wouldn't make sense for a trader to engage in this kind of behavior. The only explanations I can think of are:
1. TradeSports waives the fees for certain high-volume traders.
2. TradeSports itself engages in trading on its own exchange, something which they specifically deny in their FAQ.