and 2 “follow[ed] accordingly” from findings that the defendant was the “true source” of the money used for contributions made by conduits); United States v. Gabriel, 125 F.3d 89 (2d Cir. 1997) (dicta) (analyzing the interrelationship between Section 1001 and FECA). In most circuits, for a defendant to have “knowingly and willfully” made a false statement or have caused false statements to be made to the FEC, he or she must have known that the statement was false and he or she must have intended to act unlawfully, even if he or she was unaware of the specific reporting requirement. Most circuits have adopted this interpretation of the willful requirement in Section 1001; see also Bryan, 524 U.S. 184 (1998). Some have adopted a lesser standard. See United States v. Hsia, 176 F.3d 517, 521–22 (D.C. Cir. 1999); United States v. Hopkins, 916 F.2d 207, 214–15 (5th Cir. 1990). The Third Circuit, alone, has required the heightened showing that the defendant have also been aware of the specific statutory duty to disclose. See Curran, 20 F.3d at 570; see also Starnes, 583 F.3d at 211 (limiting Curran to “tandem violations of §§ 1001 and 2(b) in the ‘federal election law context.’”). Department policy is to apply the Bryan standard. The elements of a Section 1001 offense, in the context of false statements made to the FEC, are: • the defendant caused another to make a statement that was false; • the false statement concerned a matter that was within the jurisdiction of the Federal Election Commission; that is, the false statement related to a fact that the Federal Election Campaign Act required to be accurately reported; • the false statement was material to the FEC, that is, it had the natural tendency to influence the FEC in the performance of its official duties; and 161