• the defendant acted knowingly and willfully; that is, the defendant intended to cause the recipient to record false statements and knew, generally, that making such a false statement as unlawful. However, the government does not have to prove that the defendant was aware of the specific statutory requirements and prohibitions of FECA or that he or she was aware of the federal agency’s interest in the matter falsified. (b) Conspiracy to defraud the United States: 18 U.S.C. § 371 The “conspiracy to defraud” approach to FECA crimes is based on Hammerschmidt v. United States, 265 U.S. 182 (1924), which held that a conspiracy to defraud the United States under Section 371 includes a conspiracy “to interfere with or obstruct one of [the federal government’s] lawful governmental functions by deceit, craft, or trickery, or at least by means that are dishonest.” Id. at 188. See also, Dennis v. United States, 384 U.S. 855, 861 (1966); Haas v. Henkel, 216 U.S. 462, 469 (1910). This conspiracy theory, as applied to the functioning of the FEC, is as follows: the FEC, an agency of the United States, has the principal statutory duties of enforcing FECA’s campaign financing prohibitions and disclosure requirements and providing the public with accurate information regarding the source and use of contributions to federal candidates and expenditures supporting federal candidates. 52 U.S.C. §§ 30106 and 30107. To perform these duties, the FEC must receive accurate information from the candidates and political committees that are required to file reports under the Act. A scheme to infuse patently illegal funds into a federal campaign, such as by using conduits or other means calculated to conceal the illegal source of the contribution, thus disrupts and impedes the FEC in the performance of its statutory duties. 162