" ALL THE IRANIANS IN OUR COMPANY HAVE PASSPORTS FROM DOMINICA." HOSSEIN SHAMKAMI'S EVIL EMPIRE- THE UAE MEGA-SCANDAL

Here are ongoing developments regarding the commercial activities and sanctions-evasion network led by MOHAMMAD HOSSEIN SHAMKHANI. The organization is executing a rapid liquidation of its UAE entities, initiating mass terminations of local personnel, and transferring its command structure to China. Below is a summary of these actions. The Phantom Fleet: Inside the Terrifying Collapse of 'H' and the UAE's Billion-Dollar Shadow Empire. In the gleaming towers of Dubai, billions of dollars move in total silence. They flow through shell companies, phantom tankers, and offshore hedge funds. But beneath this veneer of corporate legitimacy lies one of the most sophisticated and dangerous sanctions-busting operations in modern history. 

At the center of it all is a man known in elite trading circles simply as "H", "Hector", or "Hugo Hayek". His real name is Hossein Shamkhani. As the son of Ali Shamkhani, Iran’s powerful former national security chief, Hossein didn't just inherit political connections—he weaponized them to build a staggering global enterprise. His syndicate—anchored by entities like the Milavous Group and the Admiral Group—controls a massive "shadow fleet" of tankers. This fleet doesn't just smuggle sanctioned Iranian and Russian crude; US officials have linked Shamkhani's maritime network to a terrifying "weapons-for-oil" pipeline, actively transporting drones, missiles, and dual-use components to fuel Russia's war machine.

But the walls are finally closing in. Following crushing sanctions from the United States Treasury and the European Union throughout 2025 and 2026, the Shamkhani syndicate is triggering a drastic, scorched-earth retreat from the Middle East. What is happening right now in Dubai is not just a corporate restructuring. It is a mass liquidation, a covert exodus, and a chilling reminder of how easily the architects of global conflict can vanish into the dark. 

The Corporate Facade: A Masterclass in Deception To evade international intelligence agencies, Shamkhani’s network operates through a labyrinth of rapid rebranding, Caribbean passports, and continuous corporate mutation. When one tentacle is severed by US authorities, two more grow in its place.Take Teodor Shipping L.L.C., a UAE-based vessel management firm explicitly sanctioned by the U.S. Treasury for orchestrating Shamkhani’s illicit shipping operations. To sidestep these penalties, Teodor was simply dissolved and quietly resurrected as Velora Shipping DMCC.

This same shell-game psychology governs the rest of his UAE portfolio: Greenharbour DMCC (Operating from the ashes of Helmatic Consultancy and Marvise Ship Management DMCC).Aureliun Management Consultancy (The financial nerve center pumping capital through the network). Lutris Consultancy LLC FZ (Previously Eastgate Consultancy LLC FZ). LX2303, API World Tower, Trade Center First, Dubai, United Arab Emirates. This acts as the syndicate's legal shield. The Head of Legal is UK national Edward Robert Newitt (Passport: 157159678), whose maritime expertise helps navigate the treacherous waters of international shipping law. Loamloaft Consultancy LLC & Irongate Consultancy LLC (Dedicated oil and gas logistics fronts).

As the economic crosshairs lock onto these entities, Shamkhani is burning the evidence. Several of his maritime operators—Glavos Shipping FZCO, Dezera Shipping FZCO, Limes Ship Management, and Bravos Ship Management—have already been quietly liquidated.

The Human Machinery: Huminara Consultancy LLC; Moving billions of dollars of contraband across oceans requires an army of brokers, logistics experts, and corporate operatives. Managing this sprawling, high-risk workforce is the sole responsibility of Huminara Consultancy LLC. Operating under Trade License (TL) 1552340 out of Office 301, Cayan Business Tower in Al Thanyah First, Dubai, Huminara is the beating heart of Shamkhani's HR infrastructure. Originally named Integraedge LLC, the firm was rebranded under the direction of its top executive to obscure its tracks as the network scaled across the UAE, Iran, and Pakistan.

The people running this HR engine are not standard corporate bureaucrats; they are the architects of a massive, multi-national shadow workforce:Sebastian Fuchs, CHRO (Passport: C4KN1TX3K): A German national serving as the Chief Human Resources Officer. Fuchs orchestrated the pivot from Integraedge to Huminara and currently oversees the entire cross-border workforce, engineering the logistics of their most dangerous move yet. Hao Wu (Passport: E96247688): A Chinese national handling the complex compensation and benefits structures that keep employees paid through a maze of sanctioned shell companies. Joyce Ann Irene Capili Oriel Bicua (Passport: P3336587B): A Philippine national serving as the on-the-ground HR Manager, handling the day-to-day administration of a workforce operating on borrowed time.

The UAE allows this activity to be conducted with impunity.

 

HOW DID BRITISH REGULATORS PERMIT A FOREIGN BANK IN EXTREMIS, WITH PENDING LITIGATION AND A SUSPENSION REQUEST, TO OPEN A REP OFFICE IN LONDON?

What on earth is going on with UK regulatory authorities? They have permitted Nevis-registered HAMILTON RESERVE BANK LTD. to open a representative office, notwithstanding protracted pending litigation against the bank, and a recent High Court Justice opining that its license should be suspended, pending a civil & criminal investigation. Doesn't anyone in the Financial Conduct Authority use Google for basic due diligence?

I realize that most of the media coverage of the multi-year civil litigation against the bank, filed by extremely unhappy clients who have been denied access to their deposits for several years, has been minimal, but even basic inquiries by the FCA would have revealed the problems. Who is watching the store there, please?

Also, given the listed address, it is obvious that the bank's rep office is purely virtual, no brick and mortar facility, with designated staff on site. Doesn't that further give regulators pause? Or was it the fact that there are British nationals on the Board of Directors sufficient to allay any suspicions? Is it the Old Boy Network again? Whatever it is, it smells of either undue influence or professional negligence. Not a good look for the FCA, to be sure.

LAW REVIEW ARTICLE CONCLUDES THAT CITIZENSHIP BY INVESTMENT PROGRAMS ARE INCONSISTENT WITH EUROPEAN POLICY, AND VISA-FREE ENTRY TO THE EU THROUGH CBI WILL BE TERMINATED

I direct your attention to the recent article, appearing in the University of Miami School of law International and Comparative Law Review, entitled WHO GETS TO SELL A PASSPORT? THE EU'S CARIBBEAN ULTIMATUM AND THE RULE THAT QUIETLY CHANGED (Vol. 33, Issue 2, 2026), which contains an objective, thorough legal analysis of the European Union's reasoning behind its ruling that there must be a "genuine link," or meaningful connection, between an individual and that "payments through a transactional procedure" are a violation of EU law; naturalization cannot be reduced to a purchase.

The author does touch, in passing, on the abject failure of Caribbean CBI and CIP states to perform effective due diligence as a national security risk factor in the EU decision, and the United States policy of effectively ending visa entry for citizens of Antigua & Barbuda, for the same reason, and remarked that such security concerns are real, citing a non-Caribbean CBI jurisdiction where inadequate due diligence allowed sanctions and prosecution evasion.

While the article is critical of the EU, for its own residency-to-citizenship programs, which require years of genuine connection with the jurisdictions offering such ultimate benefits, and it questions whether the five Eastern Caribbean states have a bona fide chance to delay, or modify, the June 2028 deadline set by the European Commission, its conclusions should serve to convince Caribbean government leaders, and their counsel, that the end is coming, and they had best start making alternative arrangements for cash flow, to cover their bloated governmental budgets, or pare them down severely, as 2028 is not merely a negotiating tool, but a reflection of national policy. Change is coming soon t0 the five Eastern Caribbean CBI states pay their bills, and they has best adapt early on, or face the consequences.

Here is the link to the article:

https://international-and-comparative-law-review.law.miami.edu/who-gets-to-sell-a-passport-the-eus-caribbean-ultimatum-and-the-rule-that-quietly-changed/

RECENT $200m PAYMENT TO HEZBOLLAH SHOWS US THAT NOBODY IS TEACHING TERRORIST FINANCING TRADECRAFT ANY MORE

Iran recently sent two hundred million dollars to Hezbollah. How on earth did this happen? A quarter of a century after 9/11, I see zero compliance training incorporating Terrorist Financing Tradecraft, the specific methods and tactics money launderers employed by designated terrorist organizations use to clean and move the millions of dollars that their clients need to. pursue their amoral goals. I realize that there are no direct threats and attacks in Europe and North America, like we sought to protect against after the events of 2001, 203 & 2005, but a whole new generation of compliance officers have come of age, been educated, and arrived on the scene, who never experienced that fear and loathing, and they are now training the next generation of frontline compliance staff, passing quickly over what I regard as critical tradecraft, in favor of traditional AML techniques. 

Ladies & gentlemen, reach back into your old files, dust off the terrorist financing tradecraft, update it and pass it down to the current generation of trainers and lecture speakers, so that they will recognize such topics as terrorist financing through charitable organizations, international trade transactions, the use of barter methods, the artful use of disinformation by terrorist laundrymen, and the dozen or so other important subjects where laundrymen for terrorist organizations ply their dark trade. Teach them well, lest they find out their bank facilitated the movement of two hundred millions dollars in 2027.

INFORMATION REGARDING AN EXTREMELY LARGE SUSPICIOUS LOAN FROM A TINY SAINT LUCIA BANK RAISES QUESTIONS ABOUT THE COUNTRY'S ROGUE OFFSHORE INDUSTRY

Apparently, the American financial media's concerns over the ongoing offshore banking scandal in NEVIS, concerning Hamilton Reserve Bank Ltd. and the Bank of New Innovation Ltd;, has focused attention on Caribbean offshore banking in general. Recent media reports concerning an extremely small offshore bank in the Eastern Caribbean state of SAINT LUCIA, ALTER BANK LTD.*, have drawn our attention to what appears to be the totally unregulated and supervised offshore banking industry in that jurisdiction.

According to published reports, Alter Bank, which has a capitalization of only USD$4m, made a loan of $290m to Mexico's second largest media conglomerate, one that is currently embroiled in major litigation with A major American bank. Where did the money for this extraordinary loan come from, and was it real? See The Bank of New York Mellon v. TV Azteca, S.A.B. de C.V. et al, 1:2022cv08164 (S.D.N.Y.)

Who is watching the store regarding financial regulation and oversight in troubled Saint Lucia? Anyone?

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* Formerly known as STATE TRUST BANK & TRUST LTD.

READ THE FILING SCHEDULE FOR THE EXPEDITED APPEAL FROM THE NEVIS HIGH COURT DECISION AGAINST BONI

Readers who are following developments regarding the BONI (BANK OF NEW INNOVATION LTD.) portion of the Omnibus 222-page Judgment that also included the Findings of Fact and Conclusions of Law against HAMILTON RESERVE BANK LTD. may want to see the details in the High Court order entered on September 24, 2026, which granted BONI'S Application for an expedited Appeal of the Judgment, and set forth the schedule of due dates for the respective appellate filings of the appellant and the respondent.

The order also directed the Chief Registrar of the court to schedule oral argument expeditiously, as soon as the filings have been received. we plan to monitor this appeal, and update our readers on all significant developments in both it and the Hamilton Reserve Bank cases, as they occur.

SUPERSEDING TERRORISM INDICTMENT AGAINST NICOLAS MADURO SHOULD HAVE ANTIGUA'S MONEY LAUNDERING BANKERS MAKING TRAVEL PLANS FOR CHINA

 

This week's announcement by the Department of Justice, adding terrorism charges to the pending Federal criminal case against NICOLAS MADURO MOROS, the former president of Venezuela, will most likely have the effect of essentially guaranteeing that he will ultimately enter a guilty plea, to avoid a potential Life Sentence, which under current law does not allow an individual so convicted to ever be released. The allegations are that Maduro was responsible for brutal torture of Americans illegally held in Venezuela during his time in office. What do you think an American jury will do with that set of facts?

Taking the probability that Maduro will be forced to plead out, in tandem with the expected testimony already believed to be in progress of the Colombian money launderer, ALEX SAAB MORAN, a perfect storm of first-hand incriminating testimony against bankers in Antigua who laundered narcotics profits with Saab, for Maduro's drug trafficking and corruption cartel, more than sufficient to convict, becomes a likely future for those individuals, as well as those senior Antiguan government officials who facilitated the laundering operations. We have previously identified the two indigenous banks that, in cooperation with two Antiguan and one Dominican offshore financial institution, move millions of Maduro's narco-profits to safe harbours abroad.

If I was to guess what route the guilty bankers, of which at least one is a British national resident in Antigua, will likely take to a new life in the Peoples' Republic of China, observers might want to look for the targets traveling to one of the more obscure islands in the French Antilles, ostensibly for medical treatment, but in truth and in fact to obscure their subsequent boarding of Air France flights, later changing planes at their European destination for Asia. They will definitely not be extraditable by their new hosts, and will probably be put to work assisting China in further expanding its  diplomatic, social, economic, linguistic and cultural influence in Antigua and Barbuda. Whether American law enforcement is able to apprehend them in transit we cannot say, but we will be watching. 

 

NEVIS REGULATORS' FAILURE TO ENFORCE FINANCIAL FILINGS ALLOWED INTERNATIONAL BANKS TO DENY DEPOSITORS ACCESS TO THEIR FUNDS WITH IMPUNITY

We note that the St. Kitts & Nevis Financial Services Regulatory Commission (FSRC) has filed a notice reminding international banks that the deadline for them to file their mandatory quarterly financial reports is October 14, which is next week. The problem is that such reports are confidential by law, and not published in any public disclosure registry and the investing public therefore cannot access them, or even obtain confirmation that they have even been filed, let alone that they reveal violations of banking law or procedure.

Our sources have confirmed that the BANK OF NEW INNOVATION, more commonly known as BONI, has never filed any quarterly reports for the entire period of 2021 to 2026. We also are aware that BDO, the designated auditors for BONI, has written to the FSRC to tell them they no longer will be the external auditor for BONI. So, given these egregious violations by BONI management, how is it that the FSRC has never initiated enforcement proceedings?

We call upon BONI, as well as HAMILTON RESERVE BANK, both of whom the High Court has urged be suspended forthwith, to publish all the quarterly financial reports for the past five years that they have filed, if any, as well as the now due for third quarter 2026 report, on or before October 14, 2026.

BENJAMIN WEY PLAYS THE RACE CARD AGAINST JUSTICE MORLEY

Justice Ian Morley KC

Benjamin Wey’s attack on Justice Iain Morley is ugly, personal and unsupported by the evidence presented. In comments displayed under Wey’s name in a supplied screenshot, Morley is branded a “white supremacist” and portrayed as a disgraced judge removed from Nevis. These accusations do nothing to answer the serious questions raised in the Hamilton Reserve Bank litigation.

Before attacking Morley’s reputation, consider his distinguished career. Beginning in 2005, he prosecuted genocide at the United Nations International Criminal Tribunal for Rwanda, helping pursue accountability for one of modern history’s worst atrocities. In 2009, he became Senior Trial Counsel at the UN Special Tribunal for Lebanon, working on the prosecution concerning the assassination of former Prime Minister Rafik Hariri. He subsequently served for years on the Caribbean bench. This is a substantial record of service to international justice.

That career does not make Morley immune from criticism. But calling him a white supremacist requires evidence. The comments in the screenshot supply none. The claim of disgraceful removal is equally questionable. The available reporting describes Morley’s move to Dominica as a regional judicial reassignment. The St Kitts–Nevis Observer itself reported it in those terms. A transfer is not proof of disciplinary dismissal.

Morley’s September 15, 2026 ruling referred concerns about Hamilton Reserve Bank to authorities for consideration of an independent investigation and possible suspension of its banking licence. Those referrals were not criminal convictions. The bank disputes his conclusions and asserts full compliance. Its response should be judged against the evidence.

Wey’s racial accusation answers none of those concerns. It shifts attention from the bank’s conduct to the judge’s identity. In my view, this is an attempt to discredit an inconvenient judicial voice through personal vilification. Wey should produce the evidence supporting the racial accusation and the claim of disciplinary removal. Until then, these statements deserve to be treated as unsupported attacks on a judge with a distinguished record of prosecuting international crimes.

If Wey believes Morley’s judgment is wrong, he should identify the legal errors. Playing the race card is no substitute for answering the Court.

PREMIER OF NEVIS, FEARING INSOLVENCY IN THE CARIBBEAN, ASKS FOR A FIVE YEAR EXTENSION ON CITIZENSHIP BY INVESTMENT PROGRAMS IN THE CARIBBEAN

The Premier of Nevis, MARK BRANTLEY, in a recent address, made the case for a minimum five-year moratorium on the termination of the five Citizenship by Investment (CBI/CIP) passport sales programs currently operational in the Eastern Caribbean states. 

Mr. Brantley argued:
(1) CBI programs account for more than half of government revenue in some jurisdictions. Demanding a swift shutdown would place immense, destabilizing pressure on local economies. Didn't regional leaders know this might come one day?
(2)Brantley argued that at least a five-year period would be reasonable to allow regional economies to transition and find alternative revenue streams. St.Kitts & Nevis has been ignoring development that could create jobs since 1983, when the CBI program opened. It has been addicted to the easy cash flow, and neglected development.
(3)He urged St. Kitts and Nevis, along with neighboring Caribbean nations operating similar programs, to actively initiate the formal bilateral negotiation mechanisms rather than quietly complying with immediate EU pressures. That sounds suspiciously like playing hardball when you don't have the proper glove to take the heat.

Of course, the possible self-destruction of Nevis' offshore industry, as the direct result of the HAMILTON RESERVE BANK/BONI financial scandals might have something to do with the Premier's concerns; if the financial revenue stream received from the offshore sector expires, Nevis might face fiscal insolvency, being unable to pay its government employees or settle obligations.

We know the Members of the EU will never agree to a five-year transition period, especially with their concerns about Russia's possible military moves against them by 2030, and Russian intelligence agents with visa-free access to Europe is facilitated by CBI, so it's not going to happen. Mr. Premier, find another legal source of cash flow for Nevis.

HAMILTON RESERVE BANK AND BONI DEFY COURT ORDER REQUIRING THEM TO DISBURSE TO DEPOSITORS, FILE APPEALS OF DEBATABLE LEGAL MERIT

The Omnibus Judgment entered on September by the High Court in Nevis ordered both Hamilton Reserve Bank Ltd. (HRB) and BONI ( Bank of New Innovation Limited) to pay their demand depositors, who have been seeking access to their accounts for years, by no later than October 29, 2026. However, rather than comply with the 222-page order of Court, which tracked their failures to remit funds on request, both offshore banks have filed appeals to the Eastern Caribbean Supreme Court. In our opinion, both cases lack merit; The Court will decide.

A fair reading of the issues raised in the appeals however, is extremely troubling to legal observers; rather than directly respond to the Court's Findings of Fact, both banks have interposed technical and procedural defenses that attempt to excuse their improper behavior which, when coupled with the banks' prior utterly dilatory and yes, even Bad Faith, legal maneuvers, lead us to conclude that these appeals may have been brought solely for the purposes of delay, and devoid of legal merit. Whether sanctions will ultimately be visited upon the banks we cannot say, but their conduct is questionable at best.

Issues raised, such as alleging Judicial Overreach and "Bizarre" blame by the Court, and adherence to US AML-BSA compliance regulations and procedure, Contradictory Calculations, Preempting Regulatory Powers and Over-reliance on Subordinate Witnesses, will all have to be considered by the appeals court, and result in an extended period of delay for the victims.Moreover, the banks will have an additional appeal as a Matter of Right to Nevis' designated Court of Last Resort, the Privy Council in the United Kingdom.

As Justice Delayed is Justice Denied, we fear that it will be many years for the appellate process to play out, which is an abject disservice to the victims, all of whom deposited a substantial sum into the respective banks, which may cause them to choose other avenues, and other targets, in their efforts to recover their money. We will be monitoring all developments as they unfold in what has become not only a matter of great public importance to the Nevis offshore industry, but investor trust in the country as a whole; stay tuned.

IS ANTIGUA FACILITATING THE EXPEDITED TRANSFER OF CHINESE INTELLIGENCE AGENTS OUT OF CUBA IN CASE OF AN AMERICAN MILITARY OCCUPATION OIF HAVANA?

Why, after all the years of China extending credit to Antigua & Barbuda, of the incestuous financial relationship between avaricious Prime Minister Gaston Browne and China's leaders, of Antiguan children being told to learn Mandarin, and of Antiguan university students being educated inside China, is Antigua just now making entry visa free? Am I missing something tactical here?

Have you watched the bellicose language both Donald Trump and Secretary Marco Rubio have displayed of late towards the regime ruling Cuba? And the ramping up of U.S. Army reserve units that could field Military Police, medical and support battalions which would be necessary administratively to control a territory under occupation? The signals are there for everybody to see.

Remember, China uses Cuba as an electronic listening post on the United States, with an emphasis on American military activity; this is called signals intelligence, and it is conducted at several locations across Cuba by senior Chinese agents. If the US enters Cuba, those individuals will not have the privileges of  diplomatic cover to protect themselves from detention, and having their documents seized.

Enter Pro-China Gaston Browne; he has now conveniently made free and instant entry into Antigua a cakewalk of Chinese intelligence agents on the run, and if they arrive accompanied by a number of senior Cuban leaders, I would not be at all surprised. Antiguans might want to be on the lookout for Fidel Castro's grandchildren if American paratroopers appear on the ground in St. John's. 

THE ISSUES REQUIRE THAT YOU RAISE COUNTRY RISK FOR NEVIS

If you have been following the nightmare for depositors who have been denied access to their funds for years at HAMILTON RESERVE BANK, whilst the Premier and regulators ignore their responsibilities, due to Conflict of Interest, and fear of the logical consequences for the offshore economy, know that there are several other issues on the horizon just as troubling for the investing public, international banks, and Western law enforcement agencies.

Nevis passed broad-based offshore gaming legislation earlier this year, and has just named its international regulator to oversee its supervision. the problem is that this individual completely dropped the ball, with both Hamilton and BONI; how can we trust him with offshore gaming, a sector that the United States has a history of being concerned about, and of taking action where warranted.

Cyber currency is totally unregulated in the Eastern Caribbean; indeed the region's banking regulator has specifically warned about the situation, and yet the Premier's real estate agent spouse has now imported bitcoin vending machines. What's wrong with this picture?

Hamilton, in defending itself from multiple depositors, has accused both local regulators and law enforcement of facilitating terrorist financing and money laundering. These allegations must be reviewed, to determine whether they have a factual basis.

Under the circumstances, compliance officers charged with the assessment of Country Risk at their financial institution should now examine these issues, and make an educated decision about elevating Country Risk to High, especially if their clients are conducting any trade or business in, or through, Saint Kitts & Nevis. Does this mean redlining all the local financial institutions, ceasing to extend credit, or accepting any new clients from that jurisdiction? You be the judge of what your Risk Appetite is, when there are serious issues that could impact revenue, Return on Investment, potential total loss, and reputation damage. Deal with Nevis at this time at your peril.

WILL FINANCIAL EXPERTS PRESENTING AT ASSET PROTECTION CONFERENCE WARN ATTENDEES AWAY FROM NEVIS SCANDAL-RIDDEN OFFSHORE ENTITY, HAMILTON RESERVE BANK?

This week, the much-anticipated ASSET PROTECTION C0NFERENCE, conducted by offshore trust expert, Attorney BLAKE HARRIS, opens in Nevis. Experts in the offshore sector, who are scheduled to present, will most likely be asked by attendees to comment on the HAMILTON RESERVE BANK litigation, and offer advice on whether it they consider it safe and prudent for investors to conduct any financial business in Saint Kitts & Nevis. The Hamilton and BONI cases have shaken the country's offshore financial industry to the core, and observers are anxious, following news that both banks intend to appeal the 222-page Omnibus Judgment by the High Court that ordered them to disburse to customers, and took a position on suspension of banking licenses.

Additionally, the Premier of Nevis, MARK BRANTLEY, who also holds the portfolio of Minister for Investment, is scheduled to appear and speak, and tough questions from attendees about his pending decision on license suspension, and on the lack of action by financial regulators will most likely be on the agenda. The role of his wife, a prominent realtor on the island, regarding her purchase of Bitcoin vending machines, given the lack of regional bank supervision, as well as the country's controversial new online gaming legislation, which has a new regulator appointed recently, will also be issues very likely to come up at question time.

Will some of the most pressing questions about the financial situation in Nevis offshore structure be asked and answered this week? We will be monitoring the event and its impact on these important issues, and reporting back to our readers, especially those who have pending litigation, or significant claims, against Hamilton Reserve Bank; stay tuned.

A CALL FOR AN INVESTIGATION OF HAMILTON RESERVE BANK'S PANAMA AFFILIATE

This request for an investigation into HAMILTON RESERVE LATAM S.A., the Panamanian affiliate of Hamilton Reserve Bank, appeared over the weekend, and we are republishing it for the benefit of our readers: