Section 37 of Title 18, United States Code, implements the Protocol to the Montreal Convention for the Suppression of Unlawful Acts Against the Safety of Civil Aviation. The international Protocol was developed in response to the Rome and Vienna airport massacres by terrorists in 1985. Section 37, which became effective on November 18, 1994, makes it a Federal crime, using any device, substance or weapon, to intentionally perform an act of violence against any person at an airport serving international aviation or to destroy or seriously damage the facilities of such an airport. Initially, § 37 was applicable only when the prohibited activity occurred within the United States or the perpetrator of the prohibited activity overseas was subsequently found in the United States. On April 24, 1996, the Antiterrorism and Effective Death Penalty Act of 1996 expanded its extraterritorial jurisdiction to also cover the prohibited activity occurring overseas when either a national of the United States is a victim or a perpetrator of the offense. See Pub. L. 104-132, § 721(g), 110 Stat. 1214, 1299.
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