Unlike the mail fraud statute, the fraud by wire statute makes no reference to the venue of the offense. Accordingly, the provisions of § 3237(a) apply, and prosecutions may be instituted in any district in which an interstate or foreign transmission was issued or terminated. See United States v. Goldberg, 830 F.2d 459, 465 (3d Cir. 1987)(Section 1343 is a continuing offense under 18 U.S.C. § 3237 "so that venue is proper in any district in which the offenses were begun, continued, or completed.").
[cited in JM 9-43.100; JM 9-43.300]