A report by the BBC suggests that the FinCen Files reveal that the United Kingdom (UK) bank HSBC was involved in numerous illegal money transfers.[27] At the time, HSBC was subject to a deferred prosecution agreement for the laundering of $881 million on behalf of the Sinaloa and Norte del Valle cartels.[2] The files also describe how Barclays Bank laundered money on behalf of Arkady Rotenberg, a close associate of Vladimir Putin, who is under sanctions for his involvement in the Ukrainian crisis.[28] The BBC further notes that the UK is judged a "higher risk jurisdiction" due to the number of the country's companies appearing in SARs.[3]