 Congress passed a new counterfeiting statute in 1816 when it created the Second Bank of the United States . In United States v. Turner ( 1833 ) , interpreting the new act , the Court held that the offense of counterfeiting was committed even if the signatures forged were those of the wrong bank officers . But , in United States v. Brewster ( 1833 ) , the Court held that the crime applied only to counterfeit bills , not counterfeit notes . 
