United States, the Supreme Court has held that this exception ‘covers only torts occurring within the territorial jurisdiction of the United States.” Cabiri v. Govt of the Republic of Ghana, 165 F.3d 198, 200 n. 3 (2d Cir.1999) (quoting Amerada Hess, 488 U.S. at 441, 109 S.Ct. 683); see also Arsh v. State