To demonstrate "trafficking," the government must produce substantial and probative evidence that the noncitizen was engaged in the business of selling or dealing in controlled substances; simple possession or transfer without consideration are not sufficient to establish illicit trafficking.  The government must also prove the essential element of intent: the specific intent to distribute controlled substances.  See, e.g., Matter of Rico, 16 I. & N. Dec. 181, 186 (1977) (finding that the petitioner was a "knowing and conscious participant" in an attempt to smuggle drugs into the United States which "brings him within the provisions of section 212(a)(23) of the Act relating to `illicit trafficker.' "); Matter of Favela, 16 I. & N. Dec. 753, 755 (1979) (upholding the IJ's finding that the alien was a "conscious participant" in an attempt to smuggle drugs into the United States and thereby excludable under section 212(a)(23)).