Escalation and reporting mechanisms require brokers to promptly report suspicious activity and submit periodic compliance summaries. Regulation 18H requires stock brokers' Audit Committee or Board to review compliance and internal controls periodically, to promptly report detected suspicious activity to stock exchanges in the prescribed manner, and to submit periodic summary analyses or 'nil reports'. Deviations in internal controls, risk management, surveillance or client onboarding policies with proposed corrective actions must be placed before the appropriate governing body and included in the periodic report; brokers may seek exchange guidance where suspected activity cannot be legally ascertained due to limited information.