What is the test for making materially false statements in response to an OFAC administrative subpoena?

[12] Counts Four and Five of the Indictment charged Banki with making materially false statements in response to OFAC administrative subpoenas, in violation of 18 U.S.C. 1001. To convict a defendant of violating Section 1001, the government must prove that the defendant: (i) knowingly and willfully, (ii) made a statement, (iii) in relation to a matter within the jurisdiction of a department or agency of the United States, (iv) with knowledge that it was false or fictitious and fraudulent. United States v. Wiener, 96 F.3d 35, 37 (2d Cir.1996).