Fourth Circuit -- US v. Osama Ayesh

Extraterritorial application of fraud statutes comported with the statutes and with due process.

Statements made during 5 hour interrogation after 19 hour (non-custodial) plane flight were voluntary for Miranda purposes.

Sufficient evidence for fraud conviction even where the government eventually received the services - diversion of the funds with intent suffices.

US v. Osama Ayesh