Pham

MEMORANDUM **

Thach Ngoc Pham appeals his convictions for conspiracy to commit bank fraud and aiding and abetting bank fraud. We affirm. The sole question on appeal is whether the evidence was sufficient to support the bank fraud convictions as alleged in counts three, four, five and nine of the indictment. In considering this challenge, we review the evidence presented against the defendant in a light most favorable to the government to determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. United States v. Pacheco-Medina, 212 F.3d 1162, 1163 (9th Cir.2000).

After a careful review of the record and the briefs submitted by the parties, we conclude that the evidence was sufficient to sustain the convictions. Pham’s primary argument is that the government did not provide evidence directly linking him to the cashed checks underlying the contested counts. However, a defendant may be convicted of aiding and abetting substantive offenses without direct evidence linking him to the commission of the substantive counts if there is sufficient circumstantial evidence to support the finding. Nye & Nissen v. United States,…