I haven’t researched this in depth to determine what constitutes a “seal” under the code. There are only a few cases in the annotation to 18 USC 1017.
Viewed in light most favorable to jury verdict, there was sufficient evidence on all of elements of crimes to support defendant’s convictions: (1) jury heard myriad witnesses and viewed numerous emails detailing scheme, theory behind scheme, and scope of fraud and connections between defendants acting in concert; (2) jury heard that defendant created copy of Department of State seal to place on cards and continually modified seal and cards to make them look more legitimate; (3) though defendant received notice that wrongfully obtaining apostille and misusing seal was illegal, he continued to market and sell cards; and finally, (4) there was evidence that defendant drafted documents to explain to potential customers why it was legal for him to use Department of State seal on cards. United States v. Goodyke, 639 F.3d 869, 2011 U.S. App. LEXIS 8452 (8th Cir. 2011), cert. denied, 565 U.S. 1172, 132 S. Ct. 1129, 181 L. Ed. 2d 1006, 2012 U.S. LEXIS 625 (2012).
In convictions of mail fraud, wire fraud, misuse of government seal, and conspiring to commit these offenses based on sale of certain mortgage modification forms that contained only minor alteration of free government mortgage modification form, jury instructions for misuse of government seal charge were proper because they made clear that, in order to convict, jury needed to find that defendants knew that seal had been fraudulently affixed to document, and jurors could not logically make such finding unless they also concluded that seal was indeed fraudulently affixed. United States v. Godfrey, 787 F.3d 72, 2015 U.S. App. LEXIS 8625 (1st Cir. 2015).
It’s the “affixes or impresses” language that implies that a seal under this law must be more than a mere printed or copied likeness. Still, feds can and do prosecute whether or not they have a good case.