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The Office of the Chief Administrative Hearing Officer (OCAHO) published a precedential final decision and order in United States v. Samuel Tominiyi Fasakin, 14 OCAHO no. 1375l (2023), a case arising under the document fraud provisions of 8 U.S.C. § 1324c. On remand from the Chief Administrative Hearing Officer, the Administrative Law Judge (ALJ) resolved the remaining issue in the case—whether complainant had met its burden of proving respondent possessed the requisite knowledge for a violation of 8 U.S.C. § 1324c(a)(2). Following a hearing with additional witness testimony and the submission of additional evidence, the ALJ found that the complainant had met its burden of proof. Accordingly, the ALJ found the respondent liable for violating 8 U.S.C. § 1324c(a)(2), ordered him to cease and desist from such violations, and—after weighing case-specific discretionary factors—imposed a civil money penalty of $1800.

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