Iysheh v. Gonzales, ___ F.3d ___ (7th Cir. Feb. 1, 2006) (federal conviction of "conspiracy to transport, receive, possess, etc. stolen motor vehicles" in violation of 18 U.S.C. 371 and 2313(a), constituted a fraud aggravated felony, under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), even though the statute did not have an element of fraud or deceit, because the record of conviction establishes fraud, since noncitizen pleaded guilty to "count one of the superseding indictment," which describes a conspiracy (1) "to defraud a financial institution ... in violation of [18 U.S.C. ] 1344"; (2) "to transport in interstate commerce [stolen] motor vehicles ... in violation of [18 U.S.C. ] 2312"; and (3) "to receive, possess, conceal, store, and sell [stolen] motor vehicles ... in violation of [18 U.S.C. ] 2313(a)" and the plea agreement established a total loss from the conspiracy in excess of $200,000).
http://caselaw.lp.findlaw.com/data2/circs/7th/051082p.pdf