United States v. Rivera-Ortiz  ·  2018-08-23  ·  U.S. District Court  ·  pin 658 F.3d at 35

"[C]ourts have concluded that the mail fraud statute, 18 U.S.C. § 1341 , the wire fraud statute, 18 U.S.C. § 1343 , and the Major Fraud Act, 18 U.S.C. § 1031 (a), all of which use the word 'scheme,' are not continuing offenses for statute of limitations purposes."

United States v. Hamdan  ·  2014-03-31  ·  Second Circuit  ·  pin 658 F.3d at 35

“As it does not appear that [defendant] disputed the inclusion of allegedly repaid amounts in the PSR or at sentencing, we do not discern any abuse of discretion on this score.”