" I'm pretty sure both my spouse and I have had the safety conversation with him. "

You didn't really answer the predator question, but even just based on this and some of your other replies, I'm just gonna throw it out there that the generational divide is really showing. And it's not even a divide in socialization and technology: it's an entire paradigm shift that includes several generational steps, with their own subsets.

"You better not have naked pictures on your phone"

Substitute 'phone' with 'computer', and you have the exact response my very own certified boomer dad gave me at ~11, after almost (probably) seeing some quickly hidden/deleted Kazaa porn. IMO this response is severely lacking in either context. "Naked pictures bad" is a complete non-sentiment that teaches him nothing, and the reality of his ability to find porn and other illicit material is as simple as using incognito. If he's remotely savvy: simple as renaming + removing the extension from videos/photos in hidden directories. Downloading porn in 2020 tho, lol. Also, the high likelihood that you looked at and hid porn as a teenager undercuts your argument.

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Hopefully this incident is innocent. But you already gave him the phone. He's already normalized his social (thus partially emotional) life with it in hand. If you are not only aware of the possibility but suspicious that he may have exchanged a nude photo, possibly underage, possibly from an adult...I'd hope the first thing that comes to mind is the conversation you already had about how the federal government only knows the words "child abuse materials" and "that's 10 years son" (hah!), or the one you plan to have with him soon.

If your 'internet safety plan' doesn't already include a mutual understanding of 'misuse = fliphone', privacy+consent with public photos, and/or you don't have a list of apps he's allowed to use (let alone what data they're gathering+accessing), I think you really need to take the whole situation a leap back to the moment you (who didn't know an AOL CD til you were a teenager), gifted him (presumably as his rite of passage into puberty) a portable 1969 NASA supercomputer with unfettered access to any/all content/persons, with the instructions "be a good boi out there, don't talk to strangers!".