Courts directly addressing the criminal intent requirement under FECA have applied the Bryan standard. United States v. Whittemore, 944 F. Supp. 2d 1003, 1006–10 (D. Nev. 2013) (“ [T]he government must prove that Whittemore knew his conduct violated some law, but it need not prove which one.”), aff’d, 776 F.3d 1074 (9th Cir. 2015), cert. denied, 136 S. Ct. 89 (2015); United States v. Danielczyk, 788 F. Supp. 2d 472, 489–93 (E.D. Va. 2011) (“[T]he Government must prove that Defendants intended to violate the law (whatever the law was).”), rev’d on other grounds, 683 F.3d 611 (4th Cir. 2012), cert. denied, 133 S. Ct. 1459 (2013). Offenders may argue that a higher standard applies: the standard articulated for willful violations of the tax code and currency structuring by the Supreme Court in Cheek v. United States, 498 U.S. 192, 201 (1991), and Ratzlaf v. United States, 510 U.S. 135, 144–45, 149 (1994), respectively. Finding the tax code and currency structuring laws particularly complex and likely to ensnare innocent conduct, the Supreme Court found “willful” as used in those cases to require knowledge of the particular statutory requirement violated. Most courts interpreting these cases have understood the intent standard articulated to thus be limited to the criminal violations related to those specific schemes. One exception is a 1994 case, United States v. Curran, 20 F.3d 560 (3d Cir. 1994), in which the Third Circuit applied the Cheek/Ratzlaf standard to the willfulness requirement for causing false statements in violation of 18 U.S.C. §§ 1001 & 2(b), where the defendant had caused a campaign treasurer to file false reports with the FEC. Since Bryan, however, most circuits have rejected such an expansion of the Cheek standard for willfulness. E.g., United States v. Hsia, 176 F.3d 517, 522 (D.C. Cir. 1999). Even the Third Circuit has appeared to retreat from this interpretation. See United States v. Starnes, 583 F.3d 196, 211–12 (3d Cir. 2009) (noting that the Cheek/Ratzlaf standard is used in only rare instances involving “highly technical statutes . . ., such as the federal criminal tax and antistructuring provisions” and that the court applied the heightened standard in Curran because of the “tandem violations of §§ 1001 & 2(b) in the ‘federal election law context’”). 153