any time. Congress may also exercise such jurisdiction over land purchased from the states for the erection of forts and other buildings. Clause 10: Offenses Against the Law of Nations Clause The Congress shall have Power ... To define and punish Piracies and Felonies committed on the high Seas, and Offences against the Law of Nations....The "Offenses Clause" was developed to address the national government's inability to conduct foreign affairs effectively under the Articles of Confederation, which left it up to states to "provide expeditious, exemplary and adequate punishment...for the infractions of the immunities of ambassadors and other public ministers..." Edmund Randolph, a delegate to the Constitutional Convention, cited this arrangement as one of the major "defects" of the Articles, since it left no consistent or uniform recourse for foreign dignitaries and merchants. At the time clause was drafted, piracy was the only universal crime that was well-defined by the law of nations, and Congress soon addressed it through a federal statute in 1790. Felonies committed in international waters had to be specifically defined by Congress pursuant to the U.S. Supreme Court decision in United States v. Furlong (1820). However, determining the grounds on which Congress can define offenses against the law of nations has been more difficult, due largely to uncertainty about the meaning of the term "law of nations" and its scope. Clause 18: Implied Powers of Congress (Necessary and Proper) Finally, Congress has the power to do whatever is "necessary and proper" to carry out its enumerated powers and, crucially, all others vested in it. This has been interpreted to authorize criminal prosecution of those whose actions have a "substantial effect" on interstate commerce in Wickard v. Filburn; however, Thomas Jefferson, in the Kentucky Resolutions, supported by James Madison, maintained that a penal power could not be inferred from a power to regulate, and that the only penal powers were for treason, counterfeiting, piracy and felony on the high seas, and offenses against the law of nations. The necessary and proper clause has been interpreted extremely broadly, thereby giving Congress wide latitude in legislation. The first landmark case involving the clause was McCulloch v. Maryland (1819), which involved the establishment of a national bank. Alexander Hamilton, in advocating the creation of the bank, argued that there was "a more or less direct" relationship between the bank and "the powers of collecting taxes, borrowing money, regulating trade between