The application of Section 1001 to campaign financing violations follows from United States v. Hansen, 772 F.2d 940 (D.C. Cir. 1985). In that case, Congressman Hansen was indicted and convicted under Section 1001 for filing false reports with the House Committee on Standards of Official Conduct under the 1978 Ethics in Government Act (EIGA). Like a portion of FECA, EIGA is essentially a disclosure statute; it applies to federal officeholders and candidates, while FECA applies to persons seeking federal office. Also like FECA, EIGA has an internal penalty that provides for non-felony sanctions. The D.C. Circuit rejected the contention that, by enacting EIGA, Congress had repealed by implication existing felony sanctions for false reports by public officials; the court held that the civil penalty in EIGA and the felony penalty under Section 1001 “produce a natural progression in penalties,” and that “those who lie on their [EIGA] forms” violate Section 1001. Hansen, 772 F.2d at 945. The use of Section 1001, in conjunction with Section 2(b), to prosecute those who willfully cause the treasurer of a political committee to submit materially false data to the FEC has been upheld by every court that has decided the issue.62 United States v. Hsia, 176 F.3d 517 (D.C. Cir. 1999); United States v. Kanchanalak, 192 F.3d 1037 (D.C. Cir. 1999); United States v. Curran, 20 F.3d 560 (3d Cir. 1994); United States v. Hopkins, 916 F.2d 207 (5th Cir. 1990); United States v. Braddock, Crim. No. 12-cr-157, 2013 WL 4441531, at *10 (D. Conn. Aug. 14, 2013); United States v. O’Donnell, Crim. No. 08-872, 2009 WL 9041223, at *6 (C.D. Cal.), aff’d, 608 F.3d 546 (9th Cir. 2010); see also United States v. Whittemore, 776 F.3d 1074, 1080 (9th Cir. 2015) (finding a jury’s conclusion that the defendant caused a false report to the FEC in violation of 18 U.S.C. §§ 1001(a)(2) Several significant false reporting cases were prosecuted during the early days of FECA, before the FEC was created. E.g., United States v. Fin. Comm. to Re-elect the President, 507 F.2d 1194, 1197–98 (D.C. Cir. 1974) (upholding convictions for willful failure to report a $200,000 cash contribution). 62 160