Are Antitrust Violations Crimes Involving Moral Turpitude?

If an alien who has no U.S. immigration status is convicted of a crime involving moral turpitude (CIMT), the alien is subject to exclusion from the United States for a minimum of 15 years. For non-U.S. executives who do business with American companies, a 15-year ban on travel to the United States is potentially a career killer. But what offenses constitute a CIMT? When a criminal antitrust violation is alleged, the 15-year ban can come into play because, pursuant to a 1996 Memorandum of Understanding (MOU), the Department of Justice considers a criminal violation of the Sherman Antitrust Act to be a CIMT. No court, however, has held that a Sherman Act violation is a CIMT.