citizenship status are automatically “material” within the meaning of this statute. Therefore, any false statement concerning an applicant’s citizenship status that is made on a registration form submitted to election authorities, or made so that the individual may vote, can involve a violation of this statute. As discussed above, the jurisdictional requirement – that the fraud be “in any election for Federal office” – is satisfied in voter registration cases whenever a false statement concerning citizenship status is made on a voter registration form because registration is unitary in every state. The jurisdictional requirement for voting cases is likely only satisfied where the ballot included a federal candidate. Proof of the willfulness element is relatively easy in cases involving false claims of citizenship because, since 1993 when the NVRA was enacted, the citizenship requirement must be stated on the voter registration form, and the form requires that the voter check a box indicating that he or she is a citizen. (b) False claims to register or vote: 18 U.S.C. § 1015(f) Section 1015(f) was enacted in 1996 to provide an additional criminal prohibition addressing the participation of non-citizens in the voting process. This statute makes it an offense for an individual to make a false statement or claim that he or she is a citizen of the United States in order to register or to vote. Unlike all other statutes addressing alien voting, Section 1015(f) expressly applies to all elections – federal, state, and local – as well as to initiatives, recalls, and referenda. Jurisdictionally, Section 1015(f) rests on Congress’s power over nationality (U.S. C ONST . art. I, § 8, cl. 4) rather than on the Election Clause (U.S. C ONST . art. I, § 4, cl. 1), which provides the basis for its broad reach. Violations of Section 1015(f) are felonies, punishable by imprisonment for up to five years. 62