The Board of Immigration Appeals (BIA) recently held in Matter of Pinzon, 26 I&N Dec. 189 (BIA 2013), that convictions under 18 USC § 1001(a)(2) for “knowingly and willfully making any materially false, fictitious, or fraudulent statement or representation” are Crimes Involving Moral Turpitude (CIMT). The holding overturns two other BIA cases, Matter of G-, 8 I&N Dec. 315, 316 (BIA 1959), and Matter of Espinosa, 10 I&N Dec. 98, 99 (BIA 1962), which both held that convictions under this statute were not CIMTs. In Matter of G- and Matter of Espinosa the BIA held that a conviction under section 1001 was not a CIMT because the statute, at the time, did not include the element of “materiality.”