What is the burden on the government to prove the intent of the accused?

First, while we agree with appellants that 1203 and 875(a) require the government to show intent, we do not agree that they require the government to show a guilty knowledge or a criminal state of mind. Duress no more negates the element of intent in this case than it did in Walker v. Endell. The government should bear no higher burden to show intent in these statutes than it did under the Alaska kidnapping statute which contained an express requirement of intent. See Walker, 850 F.2d at 473. The district court properly instructed the jury that the government did not have to prove that the defendants knew their conduct was unlawful. The defendants do not even challenge that instruction on appeal.