From the Document: "How do you commit a crime in the United States when you have never been here? According to the United States Court of Appeals for the Fourth Circuit (Fourth Circuit) in 'United States v. Elbaz' [hyperlink], you can commit a crime in the United States without being physically present by phoning it in, even though the crime in question, wire fraud [hyperlink], only applies domestically. Specifically, the Fourth Circuit recently held that the wire fraud statute could be applied to a defendant's domestic conduct in using wires located in the United States to defraud victims in the United States without having to be physically present in the United States."
CRS Legal Sidebar, LSB10799
Congressional Research Service: https://crsreports.congress.gov/