Finally, in each of the other cases cited in the BIA's decision, either fraud or intent to defraud was explicit in the statutory definition of the alien's crime. See Matter of D-, 9 I N Dec. 605, 606 (BIA 1962) ("intent to defraud the revenue of the United States" part of the statutory definition of the alien's crime); Matter of E-, 9 I N Dec. 421, 423 (BIA 1961) (alien convicted of "conspiracy to defraud the United States"); Matter of S-, 2 I N Dec. 225, 225 (BIA 1944) (alien convicted of "conspiracy to defraud the United States by counseling submission of false statements in a matter before a department of the Government"). Goldeshtein was charged neither with fraud nor with conspiracy to defraud the United States.