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Another FinCEN media statement makes no sense.

FCRO Subsection: 
Editorial Staff

One has to wonder what is happening at FinCEN's media room. As if its abolition of the possessive apostrophe in its emails isn't illiterate enough, they often make no sense. Here's an example in which both the English (American, we should say) doesn't make sense and the subject matter is, well, bemusing. Here comes the tech bit..


This is the text of the e-mail that FinCEN has sent to registered subscribers to its notices e-mail list.

FinCEN issued a notice today to remind financial institutions that Currency Transaction Reports (CTRs) will no longer be accepted in ACSII format effective June 1, 2018. Financial institutions that batch file must file using the new XML format. If a financial institution is unable, then it must revert to the discrete option to file its reports until it is able to file using the new XML format.

First, how is "batch file" a verb? Secondly, it simply does not make sense and, third, "XML format" is not new.

"XML" is a not-quite acronym standing for "eXtensible Markup Language" and it grew out of a need for a standardised information exchange format. Many software companies hate the concept but have little choice but to pretend they love it: they want to ensure that customers are locked into their software and one way of doing that is to ensure that the databases are in a proprietary format. It is one of the ways that financial institutions have been prevented from effective company-wide data analysis for financial crime purposes: what they truly need is one, huge, centralised common dataset that can be interrogated by all the applications that access and analyse that data. But that would open the door for banks, etc. to build their own enquiry engines and that would mean that big data companies would lose control of their market. One has to think: with open standards, why would anyone choose any specific software provider? The focus would shift back to the machines which companies such as IBM and Sun had thought were behind them as they made more money from software and consultancy than from boxes. Also, once the data is in a standard format, the need for constantly updating operating systems (or stacks) would be unnecessary except for security purposes. There are enormous commercial pressures to prevent XML being fully adopted, just as there are enormous commercial pressures to prevent governments, in particular, moving to any open source operating systems or desktop "office" ware.

XML has been in widespread use since the mid 1990s when, ironically, it was championed by Microsoft as an alternative to Sun's Java, although the two do fundamentally different things.

XML is under the direction of the W3 consortium, which also directs HTML, the basic language of web browsers (which, ironically, Microsoft has for most of its IE Explorer browsers, steadfastly refused to implement properly). Oddly, IBM likes XML and Sun sometimes hints that it's a Java subset (it's not, in any way at all).

In principle, XML isn't difficult - it's a bit like HTML. Readers may not realise it but they use it a lot: when readers look at our RSS news feeds, that's an XML application - and so are everyone else's.

So, FinCEN's description of XML as "new" is not only not true, it's misleading - unless it's incomplete as to the version number and it might be.

Until now, filings in batches were done simply and readers can test it out for themselves: create a spreadsheet in whatever program you have handy and save it, then export it as a "csv" file. That creates what looks like (and, amongst other things, can be read like) a file in a text editor (for example, Notepad, for Windows users). It's also often known as, amongst other things, a "comma delimited file" because each part of a record has a comma after it and that comma tells software reading the file that a new data field is starting. XML has advantages over plain text ("ASCII") in that it can include as "native" non-English character sets and accents rather than having to insert codes.