Thanks Norm.
Since @cantyk brought that to my attention yesterday, I put that file in my tns_admin folder (first the blank one to reproduce the problem, then a valid version of the file just to play with).
I've noticed, with a 19c client at least, that if a connection times out due to profile, and a valid version of oraaccess.xml is present, then I get an access violation from one of the Oracle client dll's instead of the ORA-##### for a profile disconnect. Hopefully that can be solved (seems like an oracle bug at first glance), but it's something to be aware of.
-John