Reaching Across Borders: Second Circuit Finds U.S. Jurisdiction for Overseas Crime

October 8, 2025  |  New York Law Journal

A recent Second Circuit decision underscores how, for participants in the financial markets, U.S. criminal law often seems to rule the world. In United States v. Phillips, the first criminal appeal addressing the extraterritorial reach of the anti-fraud provisions of the Commodities Exchange Act, the Second Circuit found the statute to apply to overseas trading undertaken by a defendant from whom the U.S. identity of his counterparty was intentionally concealed. In their latest article for the New York Law Journal, Morvillo Abramowitz Grand Iason & Anello PC Partners Robert J. Anello and Richard F. Albert examine the Second Circuit’s reasoning in Phillips. 

Reaching Across Borders: Second Circuit Finds U.S. Jurisdiction for Overseas Crime