9.5.1. When Financial Exploitation Is Suspected
When an employee of an IA suspects financial exploitation, they must report it up the firm’s chain of command, according to the firm’s policies and procedures. Not every employee is considered qualified to determine whether a suspicion is reasonable. This determination should be made by a qualified individual, defined as any of the following:
• An IAR
• A BD agent
• A person serving in a supervisory, compliance, or legal capacity within the firm.
Whether a qualified individual acts on a suspicion depends on whether they believe that the suspicion is reasonable. The qualif