What is the exculpatory no defense?

We engage in a five-part inquiry to determine the applicability of the exculpatory no defense. See United States v. Alzate-Restreppo, 890 F.2d 1061, 1066 (9th Cir.1989). Goland's difficulty lies in satisfying the fourth part, which asks whether his false statements (counts 17 through 20) were in response to a routine exercise of administrative responsibility. "The application of the 'exculpatory no' defense to a prosecution under section 1001 is a legal question we review independently without deference to the district court's rulings." Id.