A sentencing court can apply the two-point Guidelines § 3C1.1 obstruction-of-justice enhancement for lying, even if the defendant does not know about the federal investigation, according to this 9th Circuit opinion. That court reasoned that "[b]ecause [the defendant] willfully provided false testimony under oath after the FBI had initiated its investigation, and his perjury directly involved two of the counts of which he was convicted, the district court properly applied the § 3C1.1 obstruction enhancement."