United States Court of Appeals

FOR THE DISTRICT OF COLUMBIA CIRCUIT

Argued March 11, 2024 Decided May 17, 2024

No. 23-3080

UNITED STATES OF AMERICA,

APPELLEE

v.

EGHBAL SAFFARINIA,

APPELLANT

Appeal from the United States District Court

for the District of Columbia

(No. 1:19-cr-216)

Jennifer E. Fischell argued the cause for appellant. With 

her on the briefs were Eric R. Nitz, Justin V. Shur, and Robert 

Y. Chen. 

 

Sonja M. Ralston, Attorney, U.S. Department of Justice,

argued the cause for appellee. With her on the brief were 

Edward Sullivan and John Taddei, Trial Attorneys, Public 

Integrity Section Criminal Division.

Before: HENDERSON and WILKINS, Circuit Judges, and 

EDWARDS, Senior Circuit Judge.
2

Opinion for the Court filed by Senior Circuit Judge

EDWARDS.

EDWARDS, Senior Circuit Judge: For five years, Eghbal 

Saffarinia (“Saffarinia” or “Appellant”) was a high-ranking 

official within the Department of Housing and Urban 

Development’s Office of the Inspector General (“HUD-OIG”).

Federal law mandated that, because of his seniority and level 

of responsibility within the federal government, Saffarinia was 

required to file annual financial disclosure forms detailing most 

of his financial liabilities over $10,000. This form, the Office 

of Government Ethics (“OGE”) Form 278, allows federal 

government agencies to learn of, investigate, and evaluate

potential conflicts of interest among senior government 

officials. The disclosure requirements, in turn, promote the

ideals of ethics and transparency in the administration of the 

federal government.

One of Saffarinia’s central responsibilities within HUDOIG was the allocation of HUD-OIG’s information technology 

(“IT”) contracts. These contracts involve extensive financial 

commitments by HUD-OIG that stretch over multiple years 

and are worth tens of millions of dollars. Because the contracts 

are so lucrative, they are highly attractive to potential 

contractors.

In 2014, a contractor who lost out on a HUD-OIG contract 

filed a bid protest, resulting in an investigation that uncovered 

Saffarinia’s repeated falsifications of his Forms 278 and 

failures to disclose financial liabilities over $10,000. The 

investigation also revealed that one of the persons from whom 

Saffarinia had borrowed money was the owner of an IT 

company that had been awarded HUD-OIG IT contracts during
3

the time when Saffarinia had near-complete power over the 

agency operation.

Following a thorough investigation, the Government 

presented criminal charges against Saffarinia to a federal grand 

jury. The grand jury indicted Saffarinia on seven counts, 

including three counts of obstruction of justice under 18 U.S.C. 

§ 1519. A jury then convicted Saffarinia on all seven counts. 

The District Court sentenced Saffarinia to a year and a day in 

federal prison, followed by one year of supervised release. 

Saffarinia now appeals his conviction. First, he argues that 

Section 1519 does not extend to alleged obstruction of an 

agency’s review of Forms 278 because review of these forms 

is insufficiently formal to fall within Section 1519’s ambit. 

Second, he argues that the evidence presented at trial diverged 

from the charges contained in the indictment, resulting in either 

the constructive amendment of the indictment against him or, 

in the alternative, a prejudicial variance. Finally, Saffarinia 

challenges the sufficiency of the evidence presented against 

him at trial.

On the record before us, we can find no basis to overturn

Saffarinia’s conviction. Accordingly, we affirm the judgment

of the District Court.

I. BACKGROUND

A. Factual Background

Certain high-ranking government officials are required to 

report most financial liabilities over $10,000 via OGE Form 

278. See 5 C.F.R. §§ 2634.201(a), 2634.202(c), 2634.305. As 

noted above, these forms allow an agency to investigate 

potential conflicts of interest and ensure the propriety of 
4

agency officials’ work. The forms that are filed are reviewed 

by multiple officials within the agency, including by legal 

counsel within HUD-OIG and by an attorney in HUD’s Office 

of General Counsel whom OGE has designated as HUD’s 

“agency ethics official.”

Between 2012 and 2017, Saffarinia served as HUD-OIG’s 

Assistant Inspector General for Information Technology, and 

later as the Assistant Inspector General for Management and 

Technology. Saffarinia was part of the Senior Executive 

Service (“SES”), a class of top-ranking officials and managers 

within the federal government’s civil service. Because of his 

seniority and rank as an SES official, Saffarinia was required 

to file Forms 278 annually. 

As part of his duties within HUD-OIG, Saffarinia oversaw 

HUD-OIG’s selection of an IT Services contractor. The IT 

contract is the largest contract HUD-OIG has, with typical 

terms running five to seven years and totaling between 20 to 30 

million dollars. Prior to Saffarinia’s arrival at HUD-OIG, STG 

Incorporated (“STG”) had provided HUD-OIG with IT 

services for about a year under a short-term “bridge” contract, 

a form of contract the agency uses to maintain IT support in 

between its award of longer-term contracts. STG had also 

submitted a bid to serve the agency under a longer-term 

contract and, at least inside the agency, STG had been 

identified as the likely winner of the long-term contract. 

However, when Saffarinia assumed leadership of the operation

in early 2012, he cancelled the pending contract award to STG. 

Following the cancellation, a vice president at STG contacted 

Saffarinia to discuss how STG could best serve HUDOIG’s IT, both in its current bridge contract and moving 

forward. In a meeting with STG officers, Saffarinia suggested 

that the company consider subcontracting with Orchid

Technologies (“Orchid”), a company owned by 
5

Saffarinia’s friend, Hadi Rezazad. Saffarinia never explained

why he recommended Orchid, nor did he reveal his personal or 

financial relationship with Rezazad. Pursuant to Saffarinia’s 

advice, STG arranged for Orchid to become one of its 

subcontractors even though STG officers had never previously 

heard of the company. STG, partnering with Orchid, then won 

the HUD-OIG IT contract. 

STG’s contract was cancelled and reopened for bids a little 

more than a year later. In this round of solicitations, Orchid 

partnered with a different company and won HUD-OIG’s 

contract, which was valued at 17 million dollars. STG 

subsequently filed a bid protest. Over the next year, STG’s 

protest resulted in “multiple corrective actions,” in which 

HUD-OIG “acknowledge[d]” problems in the contracting 

process and attempted to correct them. Joint Appendix (“J.A.”) 

1074. STG ultimately alleged that Saffarinia had steered 

contracts to Orchid because of his relationship with Rezazad. 

Around the same time, Saffarinia was also accused of 

workplace misconduct and favoritism towards certain 

employees. 

Because of Saffarinia’s high-ranking position within the 

agency office normally tasked with investigating allegations of 

official misconduct, HUD-OIG could not investigate either the 

contract-steering or misconduct accusations against Saffarinia 

due to a conflict of interest. HUD-OIG therefore referred both 

allegations to the Council of the Inspectors General on Integrity 

and Efficiency (“CIGIE”), an entity required by statute to 

identify an impartial OIG to investigate allegations of 

misconduct against officials in positions such as the one held 

by Saffarinia. See 5 U.S.C. app. 3 § 11(d). 

Following an initial stage of the investigation led by the 

OIG of the Office of the Director of National Intelligence, the 
6

contract-steering allegations against Saffarinia were referred to 

the Federal Bureau of Investigation (“FBI”) for further inquiry. 

Through a yearslong inquiry conducted with assistance from 

HUD-OIG staff, the FBI learned that Rezazad had loaned 

Saffarinia $80,000 in 2013. Saffarinia had also received a 

$90,000 loan from a neighbor, Patricia Payne. Saffarinia did 

not report the loan from Rezazad on his 2014, 2015, or 2016 

Forms 278, nor did he report the loan from Payne on his 2016 

Form 278. 

B. Procedural History

A federal grand jury indicted Saffarinia on seven charges 

on June 25, 2019. Count 1 of the indictment charged Saffarinia 

with concealment of a material fact (his relationship with 

Rezazad) under 18 U.S.C. § 1001(a)(1) and (2). Counts 2-4 

charged Saffarinia with false statements, specifically his failure 

to disclose his loans from Rezazad and Payne, in violation of 

18 U.S.C. § 1001(a)(2). Counts 5-7 of the indictment charged 

Saffarinia with obstruction of justice under 18 U.S.C. § 1519, 

based on the allegation that Saffarinia had “falsely failed to 

report certain liabilities owed in the form of promissory notes”

on “forms to be filed with HUD and OGE,” with the intent to 

obstruct the “investigation” or “proper administration” of “a 

matter within the jurisdiction of a department and agency of the 

United States.” J.A. 56.

In July 2019, Saffarinia moved for a bill of particulars, 

seeking further clarification of the investigation or matter that 

underlay the obstruction-of-justice charge. The Government 

opposed the motion and the District Court denied Saffarinia’s 

request, finding that the indictment provided Saffarinia with 

sufficient notice of the matters and investigations at issue and 

explicitly identified the false statements Saffarinia was accused 

of making on his Forms 278. The District Court thus held that
7

Saffarinia had “sufficient information through discovery” to 

mount an adequate defense. United States v. Saffarinia, 422 F. 

Supp. 3d 269, 278 (D.D.C. 2019).

Saffarinia also sought to exclude evidence relating to the 

misconduct allegations. The District Court granted the motion 

in part, based on a concern over “the significant risk of unfair 

prejudice that would come from informing the jury that another 

entity investigated Mr. Saffarinia, found impropriety, and 

removed him from his position.” J.A. 776. The Government 

moved to clarify the District Court’s ruling and, in response, 

the District Court allowed the Government to explain the 

process of and provide evidence regarding the CIGIE/FBI 

investigation as evidence regarding the investigation Saffarinia 

was alleged to have obstructed. 

Following a jury trial, Saffarinia was convicted on all 

counts. Saffarinia then sought a judgment of acquittal or a new 

trial. The District Court denied Saffarinia’s motion. The

District Court subsequently sentenced Saffarinia to one year

and one day in prison. Saffarinia now appeals his conviction. 

C. Statutory Background

Passed as part of the Sarbanes-Oxley Act of 2002, Section 

1519 “instituted new penalties for fraud and obstruction of 

justice following ‘a series of celebrated accounting debacles.’”

United States v. Yielding, 657 F.3d 688, 710 (8th Cir. 2011) 

(quoting Free Enter. Fund v. Pub. Co. Accounting Oversight 

Bd., 561 U.S. 477, 484 (2010)). At the time of its passage, 

Congress was especially concerned with the destruction or 

coverup of “evidence of financial wrongdoing.” Yates v. United 

States, 574 U.S. 528, 536 (2015). The text of the statute 

provides:
8

Whoever knowingly alters, destroys, mutilates, 

conceals, covers up, falsifies, or makes a false entry in 

any record, document, or tangible object with the intent 

to impede, obstruct, or influence the investigation or 

proper administration of any matter within the 

jurisdiction of any department or agency of the United 

States . . . shall be fined under this title, imprisoned not 

more than 20 years, or both. 

18 U.S.C. § 1519. In Yates, the Supreme Court clarified the 

scope of Section 1519, tying its application to “its financialfraud mooring,” Yates, 574 U.S. at 532, and held that 

“‘[t]angible object’ in § 1519 . . . cover[s] only objects one can 

use to record or preserve information, not all objects in the 

physical world,” id. at 536.

II. ANALYSIS

A. Standard of Review

We review preserved claims of statutory interpretation, 

constructive amendment to an indictment, and variance from 

an indictment de novo. See United States v. Wilson, 290 F.3d 

347, 352 (D.C. Cir. 2002); United States v. Mize, 814 F.3d 401, 

408 (6th Cir. 2016). In considering a challenge to the 

sufficiency of the evidence to support conviction, we “must 

view the evidence in the light most favorable to the government 

and accept the jury’s guilty verdict if we conclude that any 

rational trier of fact could have found the essential elements of 

the crime beyond a reasonable doubt.” United States v. 
9

Brockenborrugh, 575 F.3d 726, 733 (D.C. Cir. 2009) 

(quotations omitted). 

B. The Scope of Section 1519

At the threshold, Saffarinia argues that his alleged 

wrongdoings are not proscribed by Section 1519. He claims:

Section 1519 requires “intent to impede, obstruct, 

or influence” one of the following: (1) an existing or 

contemplated “investigation” within a federal agency’s 

jurisdiction; (2) the “proper administration of [an 

existing or contemplated] matter” within a federal 

agency’s jurisdiction; or (3) an existing or contemplated 

“case filed under title 11 [the Bankruptcy Code].” The 

ordinary-course review of Saffarinia’s Forms 278 by 

HUD or OGE does not qualify: Neither “investigation” 

nor “matter” encompasses routine review of a form.

Brief (“Br.”) for Appellant 46. We disagree.

Section 1519 is capacious, reflecting a deliberate choice 

by Congress to capture the sorts of activity with which 

Saffarinia was charged. The text of the statute reaches anyone 

who “knowingly alters, destroys, mutilates, conceals, covers 

up, falsifies, or makes a false entry in any record, document, or 

tangible object with the intent to impede, obstruct, or influence 

the investigation or proper administration of any matter within 

the jurisdiction of any department or agency of the United 

States.” 18 U.S.C. § 1519. Here, Saffarinia was charged with 

lying on his Forms 278 – or, to use Section 1519’s words, 

“falsif[ying] . . . document[s]” – which are administered, 

reviewed, and subject to further investigation by HUD and 

OGE, both a “department or agency of the United States.”

There is little reason for us to linger over this question of 
10 

statutory interpretation: the charges against Saffarinia fit 

Section 1519’s bill.

It is undisputed that Section 1519 was passed to close 

loopholes in the existing framework of liability for obstruction 

of justice. See S. REP. No. 107-146, at 14 (2002); see also 

Yates, 574 U.S. at 536 (“Section 1519 cured . . . conspicuous 

omission[s]” in the prior regime.). “[O]bstruction of justice is 

a crime that Congress . . . has aggressively sought to deter.” 

United States v. McQueen, 727 F.3d 1144, 1159 (11th Cir. 

2013). In line with this purpose, Congress intentionally wrote 

Section 1519 as a “statute of substantial breadth.” Yielding, 657 

F.3d at 713. The Senate Report on Section 1519 explains that, 

“[w]hen a person destroys evidence with the intent of 

obstructing any type of investigation and the matter is within 

the jurisdiction of a federal agency, overly technical legal 

distinctions should neither hinder nor prevent prosecution and 

punishment.” S. REP. 107-146, at 7. The Senate Report goes on 

to make specific note that Section 1519 is “meant to do away 

with the distinctions, which some courts have read into 

obstruction statutes, between court proceedings, investigations, 

regulatory or administrative proceedings (whether formal or 

not), and less formal government inquiries, regardless of their 

title.” Id. at 15. 

Saffarinia argues that Section 1519 applies only to formal, 

adversarial, or adjudicative proceedings, not merely “formreview.” Br. for Appellant 47. There is no such limitation in 

Section 1519. “If Congress’s goal were to criminalize a subset 

of obstructive behavior, it easily could have used words that 

precisely define that subset[.]” United States v. Fischer, 64 

F.4th 329, 344 (D.C. Cir.), cert. granted, 144 S. Ct. 537 (2023). 

Here, Congress used no words, precise or otherwise, to 

reference a requirement of formality. Indeed, the legislative 

history shows its purpose was the exact opposite. With the 
11

enactment of Section 1519, Congress sought “to do away with 

the distinctions . . . some courts [had] read into obstruction 

statutes” imposing a floor of formality. S. REP. 107-146, at 15.

Nor does the Supreme Court’s interpretation of “due 

administration” in Marinello v. United States, 584 U.S. 1 

(2018), control the construction of the distinct phrase “proper 

administration” under Section 1519. In Marinello, the Supreme 

Court interpreted a clause of the Internal Revenue Code which 

made it a felony to “‘corruptly or by force’ to ‘endeavo[r] to 

obstruct or imped[e] the due administration of” the Tax Code. 

Id. at 4 (alterations in original) (quoting 26 U.S.C. § 7212(a)). 

The Court held that “‘due administration of [the Tax Code]’

does not cover routine administrative procedures that are nearuniversally applied to all taxpayers, such as the ordinary 

processing of income tax returns.” Id. (alteration in original). 

Saffarinia claims that because the Supreme Court found that 

certain routine administrative procedures did not fall within 

“due administration” of the Tax Code, HUD and OGE’s review 

of Forms 278 does not fall within “proper administration”

under Section 1519. We are not persuaded. 

Congress passed Section 1519 with text and a purpose quite 

distinct from the statute considered in Marinello. See United 

States v. Scott, 979 F.3d 986, 992 (2d Cir. 2020) (noting “the 

clear differences between the statutory language at issue in 

Marinello and that of § 1519”). Key is that Congress wrote 

Section 1519 in unmistakably broad terms, whereas such clear 

breadth was not present in the statute under consideration in

Marinello. See Marinello, 584 U.S. at 7 (finding that the “literal 

language of the statute is neutral” as to its breadth). With no 

basis in text or congressional purpose, we cannot adopt
12

Marinello’s interpretation of a different phrase in a distinct 

context to control the construction of Section 1519.

C. Constructive Amendment and Variance

Contrary to Saffarinia’s claims, we find that the 

Government neither constructively amended his indictment nor 

prejudicially varied the charges against him. Saffarinia argues 

that because the Government presented evidence about the 

CIGIE/FBI investigation to the jury, Saffarinia was convicted 

for obstruction of this investigation alone, a charge not 

contained in the indictment. There is no basis in the record to 

support this claim. 

“An amendment of the indictment occurs when the 

charging terms of the indictment are altered, either literally or 

in effect, by prosecutor or court after the grand jury has last 

passed upon them. A variance occurs when the charging terms 

of the indictment are left unaltered, but the evidence offered at 

trial proves facts materially different from those alleged in the 

indictment.” Gaither v. United States, 413 F.2d 1061, 1071 

(D.C. Cir. 1969) (footnotes omitted). In functional terms, “a 

constructive amendment changes the charge, while the 

evidence remains the same; a variance changes the evidence, 

while the charge remains the same.” United States v. Stuckey, 

220 F.3d 976, 981 (8th Cir. 2000).

Though both pertain to departures from an indictment, 

constructive amendment and prejudicial variance raise distinct 

constitutional concerns. “An amendment is thought to be bad 

because it deprives the defendant of his right to be tried upon 

the charge in the indictment as found by the grand jury and 

hence subjected to its popular scrutiny. A variance is thought 

to be bad because it may deprive the defendant of notice of the 

details of the charge against him and protection against 
13

reprosecution.” Gaither, 413 F.2d at 1071-72 (footnote 

omitted). Thus, constructive amendment bears on a defendant’s 

right under the Fifth Amendment to indictment by a grand jury 

and requires no showing of prejudice for reversal whereas a 

variance is relevant to a defendant’s right to notice under the 

Sixth Amendment and must be prejudicial to warrant reversing 

a defendant’s conviction. United States v. Adams, 604 F.3d 

596, 599 (8th Cir. 2010).

To demonstrate constructive amendment of an indictment, 

“the defendant must show that the evidence presented at trial 

and the instructions given to the jury so modif[ied] the 

elements of the offense charged that the defendant may have 

been convicted on a ground not alleged by the grand jury’s 

indictment.” United States v. Lorenzana-Cordon, 949 F.3d 1, 

5-6 (D.C. Cir. 2020) (alteration in original) (quotation omitted). 

Attention to the fit between the jury instructions and the 

indictment is particularly important as “jury instructions 

requiring the jury to find the conduct charged in the indictment 

before it may convict” provide the court with assurance that 

“the jury convicted the defendant based solely on the conduct 

actually charged in the indictment.” United States v. Ward, 747 

F.3d 1184, 1191 (9th Cir. 2014); see also United States v. Pless, 

79 F.3d 1217, 1219-20 (D.C. Cir. 1996) (no constructive 

amendment where jury could logically conclude that defendant 

was guilty of crimes charged in indictment pursuant to 

instructions given); United States v. Mize, 814 F.3d 401, 410 

(6th Cir. 2016) (no constructive amendment where jury 

instruction specifically explained that defendants could be 

convicted only of the crimes charged in the indictment).

Here, Saffarinia cannot show constructive amendment 

because there was no inconsistency between the indictment and 

the jury instructions. Quite to the contrary, the jury instructions 

closely tracked the language of the indictment. The indictment 
14 

charged Saffarinia with causing falsified forms “to be filed 

with HUD and OGE.” The District Court instructed the jury 

that to convict Saffarinia under Section 1519, they must find 

that he “acted with the intent to impede, obstruct or influence 

the investigation or proper administration of any matter or in 

contemplation of or relation to any such matter” and that “the 

investigation or proper administration of a matter was within 

the jurisdiction of HUD and OGE.” On the third element of the 

crime, the District Court specifically instructed that, to convict 

Saffarinia, the jury must “agree unanimously that Mr. 

Saffarinia acted to impede, obstruct or influence an 

investigation or proper administration of a matter by the U.S. 

Department for Housing and Urban Development, by the U.S. 

Office of Government Ethics or by both.” 

The clarity of the jury instructions and their fidelity to the 

indictment means that the jury could not have convicted 

Saffarinia solely on basis of the evidence presented regarding 

the CIGIE/FBI investigation. The jury instructions specified 

that the jury could only convict Saffarinia if it found that he 

had obstructed HUD or OGE’s investigations – no mention was 

made of CIGIE or the FBI in the District Court’s instructions. 

Accordingly, Saffarinia’s conviction is predicated either just on 

the basis of the evidence of HUD-OGE review or on the basis 

of the evidence concerning the CIGIE/FBI investigation 

considered jointly with the evidence of HUD-OGE review. 

Saffarinia’s contrary arguments are not compelling. In the 

cases Saffarinia urges us to follow, the juries did not receive 

instructions limiting the grounds upon which they could 

convict. See, e.g., United States v. Lawton, 995 F.2d 290, 294-

95 (D.C. Cir. 1993); United States v. Leichtnam, 948 F.2d 370, 

380-81 (7th Cir. 1991); United States v. Adams, 778 F.2d 1117, 

1121, 1124 (5th Cir. 1985); Stirone v. United States, 361 U.S. 

212, 214 (1960). Saffarinia counters that, despite specifically 
15 

referencing HUD and OGE, the jury instructions in his 

prosecution failed to limit the bases for conviction because the 

instructions did not explicitly name review of Forms 278 as the 

HUD-OGE investigation Saffarinia obstructed. But this would 

have been a step too far. Because HUD referred the 

investigation to CIGIE given HUD’s own inability to 

investigate in light of Saffarinia’s position, the jury could have 

plausibly found that, as a matter of fact, CIGIE and the FBI 

were acting as agents of HUD-OGE. The record before us 

amply shows that the District Court properly instructed the jury 

here. 

We also find no merit in Saffarinia’s claim that the 

Government varied the charges against him. As noted above, a 

variance must be prejudicial in order to require reversal. See 

Lorenzana-Cordon, 949 F.3d at 4 (“Variances warrant reversal 

only when the error had a substantial and injurious effect or 

influence in determining the jury’s verdict.” (quotations 

omitted)). Saffarinia cannot meet this bar. 

First, we are doubtful there was a variance. As noted 

above, whether the CIGIE/FBI investigation was within HUD 

and OGE’s jurisdiction was a question of fact for the jury to 

determine. Thus, the jury could have reasonably based its 

conviction on the understanding that CIGIE and the FBI acted 

on HUD and OGE’s behalf in pursuing the investigation into 

Saffarinia and that, in falsifying his Forms 278, Saffarinia 

intended to obstruct the investigation consisting of CIGIE and 

the FBI working at the direction of HUD and OGE. As the 

Government consistently argued before and during trial, one of 

the foreseeable consequences of Saffarinia’s falsification of his 

Forms 278 was HUD and OGE’s referral of the conflict-of-
16

interest investigation to CIGIE and the FBI. Thus, we see little 

light between the indictment and the evidence presented at trial. 

Second, even if we accept Saffarinia’s claim of variance, 

it was decidedly not prejudicial. Relevantly, “a discrepancy 

between the facts alleged in an indictment and the evidence 

actually proffered may be cause for a new trial if the divergence 

prejudiced the defendant by depriving him of notice of the 

details of the charge against him.” United States v. Emor, 573 

F.3d 778, 786 (D.C. Cir. 2009) (quotation omitted). Here, 

Saffarinia’s claim of lack of notice hinges on his discovery 

strategy: he argues that he would have reviewed the 

Government’s production differently and sought additional 

discovery had he been on notice of the Government’s intention 

to offer evidence of the CIGIE/FBI investigation at trial. 

However, as the record shows, the Government produced a 

considerable amount of discovery concerning the CIGIE/FBI 

investigation. Saffarinia fails to offer any reason to think that 

further discovery would have led him to new relevant 

information concerning the CIGIE/FBI investigation or that it

would have materially affected his honest-mistake strategy at 

trial. 

D. Sufficiency of Evidence

Finally, the record before us convincingly shows that the 

evidence presented at Saffarinia’strial was sufficient to support 

his conviction. The witness testimony presented by the 

Government demonstrated that Saffarinia’s failure to disclose 

the loans he received impeded HUD and OGE’s ability to 

investigate possible conflicts of interest. As the Government’s 

evidence made clear, HUD’s investigations of potential 

conflicts of interest depend on accurate information in 

employees’ Forms 278. Saffarinia quibbles with the formality 

with which the Forms 278 are reviewed. However, as we have 
17

already noted, his argument misunderstands the proper scope 

of the statute, which contains no formality requirement. Free 

from this misreading, there is no question that a jury could 

reasonably have found Saffarinia intended to obstruct HUD’s 

investigation into conflicts of interest or proper administration 

of its Forms 278 review based on the evidence presented at 

trial. 

As to Saffarinia’s other challenges to the jury instructions 

and the District Court’s evidentiary rulings, we find no merit in 

them. We reject these claims as well.

III. CONCLUSION

For the above reasons, we affirm the District Court’s 

judgment.