18 U.S.C. § 478
Section 478 · Foreign obligations or securities
Amended 3 times on record
Applied in 11 court decisions — leading case United States v. Karsseboom (1989)
Most recently applied in United States v. Jonathan Moody (June 2014)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Whoever, within the United States, with intent to defraud, falsely makes, alters, forges, or counterfeits any bond, certificate, obligation, or other security of any foreign government, purporting to be or in imitation of any such security issued under the authority of such foreign government, or any treasury note, bill, or promise to pay, lawfully issued by such foreign government and intended to circulate as money, shall be fined under this title or imprisoned not more than 20 years, or both.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 18, U.S.C., 1940 ed., §270 (Mar. 4, 1909, ch. 321, §156, 35 Stat. 1117).
Reference to persons causing, procuring, aiding or assisting was omitted as unnecessary as such persons are made principals by section 2 of this title.
Mandatory punishment provision was rephrased in the alternative.
Changes were also made in phraseology.
Amendments
2001—Pub. L. 107–56 substituted “20 years” for “five years”.
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000”.
Termination Date of 2001 Amendment
Amendments by title III of Pub. L. 107–56 to terminate effective on and after the first day of fiscal year 2005 if Congress enacts a joint resolution that such amendments no longer have the force of law, see section 303 of Pub. L. 107–56, set out as a Four-Year Congressional Review; Expedited Consideration note under section 5311 of Title 31, Money and Finance.