This article originally appeared in the New York Law Journal, an affiliate of the Litigation Daily.

Section 10(b) of the Securities and Exchange Act of 1934 applies only to conduct in the United States, regardless of whether liability is sought criminally or civilly, the U.S. Court Appeals for the Second Circuit held Friday.

In the latest interpretation of Morrison v. National Australia Bank, where the U.S. Supreme Court barred suits over securities sold outside of the United States, the Second Circuit said the same logic of Morrison applies to criminal activity that occurs abroad.