This practice advisory provides background and analysis on recent decisions issued by the Board of Immigration Appeals (BIA) regarding immigrating through a marriage-based petition. From 2019 to 2021, the BIA published four decisions relating to sham, or fraudulent, marriages and INA § 204(c). A sham marriage is one that the parties enter into not to establish a life together but rather to circumvent immigration laws. Section 204(c) bars approval of a visa petition where the beneficiary has previously participated in a fraudulent marriage or has attempted or conspired to do so. This bar has no temporal limitation and impedes a client’s ability to obtain permanent resident status, regardless of how much time has passed since the alleged fraud or how compelling the equities are in the current case. If USCIS makes a section 204(c) finding, this finding will forever bar approval of an I-130 family visa petition, an I-140 employment-based petition, and a VAWA-based I-360 self-petition.