“[W]e did not go so far as to hold that obstruction offenses must involve interference with an ongoing investigation or proceeding,” the Board wrote. “[O]ur point was to emphasize that obstruction of justice is not an open-ended term covering all offenses ‘that have a tendency to, or by their nature do, obstruct justice.’” Matter of Valenzuela Gallardo, 25 I&N Dec. at 842 (quoting Matter of Espinoza, 22 I&N Dec. 889, 894 (BIA 1999)).What the “obstruction of justice” aggravated felony category does require, the Board went on to hold, is “the affirmative and intentional attempt, with specific intent, to interfere with the process of justice.” Matter of Valenzuela Gallardo, 25 I&N Dec. at 841.