18 U.S.C. 1028(a)(3) (knowingly possessing five or more identification documents with the intent unlawfully to use or transfer -- other than those issued lawfully for the use of the possessor, authentication documents or false identification documents).

Immigration counsel can argue that this offense is not a crime of moral turpitude, along the following lines. If a person allows someone use his or her health insurance identification, so that they can be admitted to the hospital for a life-threatening emergency, but intends to pay the cost of the medical care, that would not involve moral turpitude. If the crime really has no element requiring intent to use at all, it might not be pure malum prohibitum, but it could be like the (non-CIMT) offense of mere possession of false documents addressed in Matter of Serna, 20 I. & N. Dec. 579 (BIA 1992), or the possession of burglary tools-is-not-a-CIMT case. Guarino v. Uhl, 107 F.2d 399 (2d Cir. 1939) (conviction of possession of burglary tools with intent to commit a crime, in violation of New York Penal Law 408, does not involve moral turpitude unless the record of conviction affirmatively shows that the particular crime the noncitizen intended to commit with the burglary tools found in his possession involves moral turpitude).