deference. 52 U.S.C. §§ 30106(b)(1), 30107(a)(7)-(8), & (e); FEC v. Democratic Senatorial Campaign Comm., 454 U.S. 27, 37 (1981). The FEC pursues FECA violations under the statutoryscheme set forth in Section 30109(a). In brief, civil penalties can be imposed through a “conciliation” process, which is roughly equivalent to an administrative guilty plea with a stipulated penalty agreed upon by the FEC and the respondent; civil penalties can also be imposed through a civil suit brought by the FEC in federal district court. Civil sanctions range from “cease and desist” agreements (in which the respondent agrees not to commit a similar violation in the future) to relatively substantial fines. The size of the civil fine depends both on the amount involved in the violation and the degree of knowledge and intent of the respondent. 52 U.S.C. § 30109(a)(5) & (a)(6). The FEC possesses subpoena power and the power to administer oaths, § 30107(a)(3) & (a)(2), as well. Criminal prosecution under FECA can be pursued before civil and administrative remedies are exhausted. § 30109(a) & (d); see United States v. Int’l Union of Operating Eng’rs, Local 701, 638 F.2d 1161, 1162–68 (9th Cir. 1979); see also Marcus v. Holder, 574 F.3d 1182, 1184–86 (9th Cir. 2009); Fieger v. U.S. Attorney Gen., 542 F.3d 1111, 1119 (6th Cir. 2008); Bialek v. Mukaskey, 529 F.3d 1267, 1271 (10th Cir. 2008). The BCRA amendments to FECA in 2002 significantly enhanced the criminal penalties for willful violations of FECA. BCRA did so in response to identified anti-social consequences, namely, corruption and the appearance of corruption arising from FECA violations, and the consequent adverse effect on the proper functioning of American democracy. These issues are addressed comprehensively in the Supreme Court’s decision in McConnell v. Fed. Election Comm’n, 540 U.S. 93 (2003). Accordingly, all willful FECA violations that exceed the applicable jurisdictional floor specified in the Act’s criminal provision 151