Domestic transaction was sufficiently irrevocable to establish culpability under the statute, despite the fact that the transaction would later have to be cleared by foreign banks -- any possible cancellation would come from the closing entity, not the counterparty.
Given the substantial connections to the US, including citizenship of the defts and the place of the transaction, the ties are sufficient to overcome the presumption against extraterritoriality.
http://www.ca2.uscourts.gov/decisions/isysquery/a2f2ecf0-a8b8-4c4b-b175-158f6c9eca38/3/doc/17-1375_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/a2f2ecf0-a8b8-4c4b-b175-158f6c9eca38/3/hilite/
