Wire Fraud Statute Reaches Communications Between U.S. and Non-U.S. Actors

The World in U.S. Courts: Spring 2014 - White Collar Criminal | January.17.2014

United States v. Lyons, U.S. Court of Appeals for the First Circuit, January 17, 2014

Defendants operated a gambling business in Antigua and were convicted of wire fraud and related violations. Among other arguments, they sought reversal of their convictions in the U.S. Court of Appeals in Boston on grounds that the Wire Act under which they were convicted had been improperly applied to conduct occurring outside the U.S. The Court of Appeals disagreed, noting that the presumption that U.S. laws were to apply only to conduct in the U.S. was not applicable to the Wire Act, which specifically covered frauds executed in U.S. or foreign commerce.

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