internal or external records). Conspiracy and fraud offenses are governed by U.S.S.G. § 2C1.1. Courts have held that Section 2C1.1 applies only to conspiracies to defraud that harm the government “in a manner similar to bribery offenses,” although such a limitation is not apparent on the face of the guideline language. See United States v. Huizar-Velazquez, 720 F.3d 1189, 1191 (9th Cir. 2013); see also United States v. Orsburn, 525 F.3d 543, 544 (7th Cir. 2008) (Section §2C1.1 does not apply to “simple theft by public officials”); Rowland, 2015 WL 1275655, at *2 (holding that Section 2C1.8, rather than Section 2C1.1, applied to defendant’s conviction for obstructing an FEC investigation). False statement offenses that occur after January 25, 2003, are governed by FECA guideline pursuant to the crossreference for fraudulent statements in U.S.S.G. § 2B1.1(c)(3). (4) Patronage offenses. To date, there has been no jurisprudence addressing the application of the sentencing guidelines to patronage offenses. Some of these crimes (e.g., 18 U.S.C. §§ 600, 601) may be governed by the fraud guideline, U.S.S.G. § 2B1.1. Others (e.g., 18 U.S.C. §§ 602, 606, 610) may be governed by the robbery and extortion guideline, U.S.S.G. § 2B3.1. A few do not appear to be governed by any guideline, and thus would be handled for sentencing purposes under U.S.S.G. §§ 2X5.1 or 2X5.2. B. CONVICTIONS INVOLVING CORRUPTION OF THE ELECTORAL PROCESS The guideline that governs sentencing for convictions that involve corruption of the electoral process is U.S.S.G. § 2H2.1. By its terms, this guideline applies to corruption of the electoral process regardless of the type of scheme involved or federal statute it violates. The guideline provides for three 173