Yeremin v. Holder, 738 F.3d 708 (6th Cir. Apr. 16, 2013) (federal conviction of one count of violating 18 U.S.C. 1028(f), for conspiracy to traffic in identification documents in violation of 18 U.S.C. 1028(a)(3), which prohibits knowingly possessing with intent to use unlawfully or transfer unlawfully five or more identification documents or false identification documents, which requires proof of an intent to use or transfer the identification documents or false identification documents unlawfully, is a crime involving moral turpitude because fraud or deceit is inherent in the elements of the offense); citing Matter of Flores, 17 I. & N. Dec. 225, 228-230 (BIA 1980) (federal conviction for uttering or selling false or counterfeit paper relating to registry of aliens with knowledge of their counterfeit nature . . . inherently involves a deliberate deception of the government and an impairment of its lawful functions, and that therefore fraudulent conduct is implicit in the statute, even absent a requirement of a specific intent to defraud; the government need not have been defrauded out of money or property for moral turpitude to be involved; rather, [i]t is enough to impair or obstruct an important function of a department of the government by defeating its efficiency or destroying the value of its lawful operations by deceit, graft, trickery, or dishonest means.), superceding Yeremin v. Holder, 707 F.3d 616 (6th Cir. Feb. 14, 2013).

NOTE: This decision preceded Moncrieffe and Descamps, and the basis for the courts argument, i.e., that an offense can inherently involve fraud even when there is no such express element in the statute, has arguably been abrogated.