Does FinCEN support Unicode characters?

Hummingbird fully supports the use of Unicode characters in your investigations, as well as your filings with local jurisdictions. For a quick primer on Unicode, this is the universal character set that allows computers to display special characters, symbols, and the vast majority of foreign language characters. The fact that you can see the characters 🎉, 大, ö, and Ω on your computer is thanks to Unicode.

Is every Unicode character supported by FinCEN?

When it comes to filing with FinCEN, they support most visible Unicode characters in their filings, but we have discovered over the years that there are specific characters that they don't support. FinCEN's own guidance suggests removing, "...non-printable characters, such as carriage returns, line feeds, and tabs". This guidance is not as clear as you might suspect, but Hummingbird works hard to ensure that these non-printable characters are removed or replaced in your filing, if detected. This ensures that your filing is received and processed by the FinCEN system in a timely manner, without errors.

Over the years, we've found a wide range of Unicode characters that FinCEN cannot ingest. This includes non-breaking spaces, line separators (which are different from carriage returns), and ideographic spaces. The number of non-visible Unicode characters is large, and FinCEN does not provide guidance on exactly which characters they do and do not support. We are working with FinCEN to help develop and refine that list of characters. Every time we discover a new character that is not supported, Hummingbird upgrades its validation system to ensure that it's removed from all filings moving forward.

How would these special Unicode characters make it into my filing?

It's common to write-up your findings about a case in another program, such as Google Docs or Microsoft Word. Once the write-up is finished, it's then copied and pasted into Hummingbird. These external programs will commonly insert special Unicode characters as part of their formatting, in order to help the text appear in the way that you've directed, or is aesthetically pleasing. When the text is copied and pasted into Hummingbird, the Unicode characters come with it.

If you have any questions about Unicode support by either Hummingbird or FinCEN, feel free to reach out to [e-mail].