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153230P.pdf   08/26/2016  Charles Sokpa-Anku  v.  Loretta E. Lynch
   U.S. Court of Appeals Case No:  15-3230
   Petition for Review of an Order of the Board of Immigration Appeals   
   [PUBLISHED] [Loken, Author, with Wollman and Benton, Circuit Judges] 
   Petition for Review - Immigration. The BIA did not err in finding that 
   petitioner's three fraud counts of conviction were part of a sufficiently 
   interrelated fraud to warrant aggregation of the losses, whether or not 
   the criminal complaint included an express allegation of conspiracy or 
   scheme to defraud; likewise, the order to pay an aggregated restitution 
   amount demonstrated that petitioner did not commit multiple, unrelated 
   frauds; as a result, he was properly ordered removed for having committed 
   an aggravated felony by committing an offense involving fraud which 
   resulted in a loss exceeding $10,000.