entity that was not paid alleges that it intended to transfer the funds to the United States on receipt. When funds are due abroad and not paid, the direct effects occur abroad. Although the entity might ultimately feel the financial injury at home in the United States, we have held that those reverberations are too attenuated to qualify as direct effects. Am. Telecom, 501 F.3d at 541; see Guirlando v. T.C. Ziraat Bankasi A.S., 602 F.3d 69, 78 (2d Cir.2010) (noting that “the mere fact that a foreign state’s commercial activity outside of the United States caused physical or financial injury to a United States citizen is not itself sufficient to constitute a direct effect in the United States”); Big Sky Network Can., Ltd. v. Sichuan Provincial Gov’t, 533 F.3d 1183, 1191 (10th Cir.2008) (<HOLDING>); Antares Aircraft, L.P. v. Fed. Republic of
holding that the fourteenth amendment which makes persons bom in the united states and subject to its jurisdiction citizens of the united states and requires that representatives be apportioned among the states based on population excluding indians not taxed did not make an indian a citizen of the united states holding that a diversity suit cannot be maintained against a partnership one of the partners of which is a united states citizen domiciled abroad holding that sovereign immunity does not bar extinguishment of united states junior lien in proceeding in which united states was not a party holding that failure to receive promised funds abroad will not qualify as a direct effect in the united states  holding that the united states adoption of a states seizure of currency has the same effect as if the united states had originally seized the currency