Nonetheless, the Pauldino principle, consistent with the rule that criminal statutes should be strictly construed, has still been applied to securities other than traveler's checks since the 1968 amendment. United States v. Boone, 470 F.2d 908, 910 (4th Cir. 1972). Other courts have held that insertion of the name of a fictitious payee may turn a genuine money order into one which is "falsely made" and therefore under the purview of 18 U.S.C. § 2314.
The legislative history of 18 U.S.C. § 2314 compels us to conclude, as have the Eighth Circuit in Streett v. United States, 331 F.2d 151 (8th Cir. 1964), and the Ninth Circuit in United States v. Simpson, 577 F.2d 78 (9th Cir. 1978), that Congress intended the third paragraph of 18 U.S.C. § 2314 to reach only forged securities, not forged endorsements, and that the forgery of an endorsement on a security which is complete and genuine at the time of the forgery does not render the security a forged security within the meaning of the statute. See United States v. Roby, 499 F.2d 151 (10th Cir. 1974); United States v. Boone, 470 F.2d 908 (4th Cir. 1972); Pauldino v. United States, 379 F.2d 170 (10th Cir. 1967). As originally enacted, section 2314 did not specifically include within its scope the interstate transportation of forged securities, but extended only to interstate transportation of, inter alia, stolen securities of the value of $5,000 or more. National Stolen Property Act of May 22, 1934, ch. 333, 48 Stat. 794 (current version at 18 U.S.C. § 2314, ¶ 1).
United States v. Braverman, 376 F.2d 249 (2d Cir. 1969) also holds that evidence of prior and subsequent acts are admissible and probative of the knowledge required by 18 U.S.C. § 2314. See United States v. Boone, 470 F.2d 908 (4th Cir. 1972); McGee v. United States, 402 F.2d 434, 437 (10th Cir. 1968). Nor can we agree that the evidence concerning the stamp sale was "cumulative and unnecessarily prejudicial."