Does a defendant have to make a further showing in order to obtain relief under the Sixth Amendment?

7 We have held the following to be per se violations of the Sixth Amendment, requiring no further showing in order for the defendant to obtain relief: "(1) where the attorney was not licensed to practice law because he failed to satisfy the substantive requirements of admission to the bar, and (2) where the attorney was implicated in the defendant's crime." United States v. O'Neil, 118 F.3d 65, 71 (2d Cir.1997), cert. denied, --- U.S. ----, 118 S.Ct. 728, 139 L.Ed.2d 666 (1998). No such claims are at issue here.