No, I can't say for sure, but it is A reason to terminate the account, and since this post is called 'Apple is threatening to terminate my developer account wit

No, I can't say for sure, but it is A reason to terminate the account, and since this post is called 'Apple is threatening to terminate my developer account with no clear reason' I believe it is the case. We will never know the real reason as Apple probably won't provide it, but there is a violation of their rules, even if the termination was because something else, they are still entitled to close it based on the violation.