(D)  Foreign Judicial Recommendations Against Deportation Ineffective.  A JRAD issued by a foreign tribunal does not preclude deportation or exclusion on the basis of a foreign conviction.[177]

[177] Mercer v. Lence, 96 F.2d 122 (10th Cir.), cert. denied, 305 U.S. 611 (1938); Matter of F, 8 I. & N. Dec. 469 (BIA 1959) (conviction of crime involving moral turpitude by foreign court martial is competent to sustain deportability under section 241(a)(1) of 1952 act based upon inadmissibility at the time of entry), distinguishing Gubbels v. Hoy, 261 F.2d 952 (9th Cir. 1958) (deportation statute refers only to sentences imposed by civil criminal courts, and a fortiori sentences imposed by military tribunals are not within their contemplation); Matter of B, 7 I. & N. Dec. 166 (BIA 1956).  See N. Tooby, Post-Conviction Relief for Immigrants § 8.25 (2004).

Other

SAFE HAVEN - STATE REHABILITATIVE RELIEF - PRIOR FOREIGN CONVICTION DOES NOT DISQUALIFY DEFENDANT FROM FFOA TREATMENT
The Federal First Offender Act, 18 U.S.C. 3607(a)(1), does not permit an expungement if the defendant has prior to the commission of the current offense suffered a conviction under "Federal or State" law. This provision does not include foreign convictions as a disqualification for this relief.