In United States v. Bowman, 260 U.S. 94, 98, 43 S.Ct. 39, 41, 67 L.Ed. 149 (1922), the Supreme Court held that a criminal statute prohibiting conspiracy to defraud a corporation in which the United States is a stockholder applied extraterritorially, despite Congress' failure to indicate that the statute should be so applied. In Bowman, the Court explained that, if a statute is to be applied extraterritorially, "it is natural for Congress to say so in the statute, and failure to do so will negative the purpose of Congress in this regard." Id. at 98, 43 S.Ct. at 41. The Bowman Court then noted, however, that "the same rule of interpretation should not be applied to criminal statutes which are, as a class, not logically dependent on their locality for the Government's jurisdiction, but are enacted because of the right of the Government to defend itself against obstruction, or fraud wherever perpetrated." Id.