HSBC Military Audit

1. Executive Intelligence Summary

1.1 Audit Mandate and Scope

This report constitutes a comprehensive forensic audit commissioned by the Defense Logistics Analysis division. The primary objective is to evaluate the extent of HSBC Holdings plc (and its global subsidiaries, collectively “HSBC”)’s involvement in the financial sustainment of the State of Israel’s military apparatus, defense industrial base, and settlement enterprise in the Occupied Palestinian Territories (OPT). The audit was conducted in strict accordance with the Core Intelligence Requirements (CIRs) defined in the mission profile:

1. Direct Defense Contracting: Assessment of direct financial relationships with the Israeli Ministry of Defense (IMOD) or Israel Defense Forces (IDF).
2. Dual-Use & Tactical Supply: Evaluation of financing provided to manufacturers of ruggedized, mil-spec, or dual-use equipment utilized in combat operations.
3. Logistical Sustainment: Investigation of financial flows supporting the physical infrastructure of the occupation, including bases, prisons, and settlements.
4. Supply Chain Integration: Analysis of capital support provided to “Tier 1” defense primes integrated into the IDF supply chain.

The audit period spans from the landmark divestment events of 2018 through the fiscal year ending 2024, with forward-looking projections into 2025 based on available financial disclosures and strategic reports. The methodology integrates forensic financial analysis, corporate policy review, and open-source intelligence (OSINT) regarding weapons system deployment in the Gaza and West Bank theaters.

1.2 Strategic Verdict: High-Level Structural Complicity

The forensic assessment concludes that HSBC maintains a High-Level Structural Complicity in the Israeli defense and occupation sectors. While the bank successfully executed a reputational maneuver in 2018 by publicly divesting from Elbit Systems, forensic evidence from 2024 and 2025 indicates a material regression in this stance, characterized by the “passive” re-acquisition of defense assets and the uninterrupted provision of liquidity to the broader defense industrial base.

Key Forensic Findings:

• Recidivism in Elbit Systems Holdings: Despite the highly publicized 2018 divestment, HSBC has re-entered the shareholder register of Elbit Systems. As of November 2025, HSBC held approximately 16,317 shares in the Israeli defense contractor, valued at over $8.3 million. This represents a 27.22% increase in holdings within a single quarter, signaling a failure of the exclusion mechanisms established post-2018.¹
• Systemic Financing of the F-35 Supply Chain: HSBC serves as a critical financial node for the multinational F-35 Joint Strike Fighter program. Through massive syndicated loans and bond underwriting for BAE Systems (UK), Lockheed Martin (US), and Raytheon (US), HSBC provides the working capital necessary for the production of airframes, electronic warfare suites, and munitions used extensively by the Israeli Air Force (IAF).²
• Sustainment of the D9 Bulldozer Fleet: The audit identifies HSBC as a participant in the Revolving Credit Facilities (RCF) of Caterpillar Inc., most recently renewed in August 2024 and August 2025. These facilities provide the liquidity required for Caterpillar to maintain operations, despite the documented weaponization of its D9 bulldozers for home demolitions and combat engineering in Gaza.⁵
• Infrastructure of Annexation: HSBC ranks among the top European creditors to companies operating in illegal Israeli settlements. The bank provides financing to entities such as Shapir Engineering and Shikun & Binui, which are responsible for constructing the Jerusalem Light Rail (JLR) and settlement housing units, thereby financially underwriting the physical infrastructure of annexation.⁸

1.3 The Mechanics of “General Corporate Purposes”

A central theme of this audit is the utilization of “General Corporate Purposes” (GCP) financing as a mechanism to bypass ethical restrictions. While HSBC’s Defence Equipment Sector Policy ostensibly restricts financing for controversial weapons (e.g., cluster munitions), it permits unrestricted lending to the parent companies of weapons manufacturers under the guise of general corporate operations. This audit establishes that GCP financing is fungible; capital provided to BAE Systems or Caterpillar for “general purposes” frees up internal resources for the development and export of military-specific hardware to Israel, rendering the policy distinction operationally void in the context of material complicity.²

2. Methodology and Financial Complicity Framework

To accurately assess HSBC’s role, it is necessary to define the mechanisms by which a financial institution supports military logistics and occupation infrastructure. Complicity in this context is not limited to the direct purchase of weapons but extends to the provision of the financial oxygen—credit, liquidity, and insurance—that allows defense contractors and settlement developers to operate.

2.1 The Hierarchy of Financial Support

The audit evaluates support across three tiers of financial engagement, weighted by their impact on the recipient’s operational continuity.

Tier 1: Revolving Credit Facilities (RCFs) & Direct Lending

This is the most critical form of support. RCFs act as a corporate “credit card,” providing the daily liquidity defense firms need to purchase raw materials, pay wages, and manage cash flow gaps between government contract payments.

• Operational Impact: Without access to RCFs, defense contractors like Caterpillar or BAE Systems would face liquidity crises, potentially halting production lines.
• HSBC’s Role: HSBC frequently acts as a “Mandated Lead Arranger” or “Bookrunner” in these syndicates, signaling high-level strategic support.⁶

Tier 2: Underwriting and Bond Issuance

When defense firms need to raise large-scale capital for R&D (e.g., developing a new drone variant) or acquisitions (e.g., Elbit buying IMI Systems), they issue corporate bonds.

• Operational Impact: Banks “underwrite” these bonds, guaranteeing their sale to investors. This facilitates the long-term expansion of the defense industrial base.
• HSBC’s Role: HSBC is a dominant player in the debt capital markets, regularly underwriting bonds for US and UK defense primes supplying Israel.¹²

Tier 3: Asset Management and Custodial Holdings

This involves holding equity (shares) in a company. While often described by banks as “passive” or “client-driven,” significant institutional shareholding provides three benefits to the defense firm:

1. Capital Cost Reduction: High demand for shares lowers the cost of equity capital.
2. Management Validation: Institutional investors vote at Annual General Meetings (AGMs) on executive pay and board appointments.
3. Market Signaling: The presence of a blue-chip bank like HSBC on the register legitimizes the defense firm to other investors.

2.2 Definitions of Complicity

• Direct Complicity: Knowingly assisting in a violation of international humanitarian law (e.g., financing a specific shipment of white phosphorus).
• Indirect/Structural Complicity: Providing financial services to a company known to be involved in systematic violations, where those services are essential for the company’s general operations (e.g., a general loan to Elbit Systems).⁸

3. Forensic Analysis: The Elbit Systems Case Study

Target: Elbit Systems Ltd. (Haifa, Israel) Relevance: Israel’s largest private arms manufacturer; primary supplier of Hermes 450/900 drones, artillery systems, and electronic warfare suites to the IDF.¹³

3.1 The 2018 Divestment: A Temporary Victory

In December 2018, HSBC confirmed it had fully divested from Elbit Systems. This decision followed a sustained campaign by War on Want and the Palestine Solidarity Campaign, which exposed Elbit’s acquisition of IMI Systems (formerly Israel Military Industries). IMI was a known producer of cluster munitions, a category of weapon explicitly prohibited under HSBC’s defense policy.¹⁴

• The Mechanism: HSBC placed Elbit on its “Excluded List,” preventing its asset management division from purchasing shares for its active funds.
• Public Impact: The divestment was widely cited as proof that BDS (Boycott, Divestment, Sanctions) tactics could force major financial institutions to align with human rights standards.¹⁴

3.2 The 2024-2025 Recidivism: Breaking the Exclusion

Forensic data from late 2024 and throughout 2025 indicates that the 2018 firewall has been breached. The audit identifies a resurgence of HSBC capital in Elbit Systems, driven largely by the bank’s asset management arm.

3.2.1 Quantitative Holdings Data

As of November 2025, investigative reports confirm that HSBC holdings in Elbit Systems stood at 16,317 shares, with a market value of approximately $8.3 million. Crucially, the data reveals a trend of accumulation, with holdings increasing by 27.22% in the quarter leading up to November 2025.¹

3.2.2 The “Passive” Loophole

Financial institutions often defend such holdings by categorizing them as “passive” or “custodial.”

• Index Tracking: HSBC Asset Management operates funds that track global indices (e.g., MSCI World, aerospace sector indices). As Elbit Systems is a constituent of these indices (traded on NASDAQ and TASE), HSBC’s algorithms automatically purchase shares to minimize tracking error.
• Custodial Services: HSBC acts as a custodian for wealth management clients who wish to invest in Elbit. While HSBC does not own the economic benefit of these shares, it facilitates the trade and holds the legal title.
• Forensic Rebuttal: The distinction between “active” and “passive” is irrelevant to the victim of a drone strike. By including Elbit in its index funds, HSBC directs client capital to the company. By acting as a custodian, it provides the market infrastructure necessary for Elbit’s shares to be liquid and tradable. The re-appearance of shares suggests HSBC removed Elbit from its central “Exclusion List,” allowing these passive mechanisms to re-engage.¹

3.3 Elbit’s Operational Relevance in 2024-2025

The re-investment coincides with a period of intensified production for Elbit. Following October 2023, Elbit ramped up production of:

• “Iron Sting” Mortar Munitions: Precision-guided mortar bombs used in urban warfare in Gaza.
• Hermes 900 “Kochav”: The primary MALE (Medium Altitude Long Endurance) drone used for surveillance and targeted strikes.
• Digital Army Program: Command and control systems integrating infantry with air support.¹³

Intelligence Verdict (CIR 1 & 4): HSBC has effectively re-integrated Elbit Systems into its investment universe. The 2018 divestment is no longer operative. HSBC capital is currently invested in the manufacturer of the primary unmanned aerial platforms used over Gaza.

4. Supply Chain Integration (CIR 4): Financing the “Tier 1” Defense Primes

While Elbit is the primary Israeli target, the IDF relies heavily on imported platforms from US and UK defense giants. HSBC’s complicity is most profound in its support for these “Tier 1” primes: BAE Systems, Boeing, and Raytheon.

4.1 BAE Systems and the F-35 Joint Strike Fighter

Target: BAE Systems plc (London, UK)

Role: Key partner in the Lockheed Martin F-35 program (manufacturing the rear fuselage and electronic warfare systems); supplier of naval guns and munitions.

4.1.1 The Financial Umbilical Cord

HSBC, as a UK-headquartered bank, is one of the primary bankers for BAE Systems.

• Revolving Credit Facilities: HSBC participates in BAE’s multi-billion pound syndicated credit facilities. These loans are for “general corporate purposes,” allowing BAE to manage its global cash flow.²
• Shareholding: HSBC is a major institutional investor in BAE Systems. Following the Russian invasion of Ukraine and the Gaza escalation, defense stocks surged. HSBC’s asset management division has maintained and likely increased its exposure to BAE to capture this “defense premium”.¹⁹
• Advisory Services: HSBC provides advisory services for mergers and acquisitions (M&A) within the defense sector, facilitating industry consolidation.

4.1.2 The F-35 Connection

The F-35I “Adir” is the tip of the spear for the IAF. It is used for penetrating Syrian airspace and conducting precision strikes in Gaza.

• Supply Chain Link: BAE Systems manufactures approximately 15% of every F-35 airframe. By financing BAE, HSBC effectively finances 15% of the F-35 program.
• White Phosphorus & Munitions: While BAE denies current production of white phosphorus, historical links remain a point of contention. More directly, BAE supplies the guidance kits and components for munitions used by the F-35.³

4.1.3 Protests and Direct Action

The link between HSBC, BAE, and the F-35 has made HSBC branches a target for direct action. In December 2025, protests targeted 11 HSBC branches across the UK (e.g., Catford, Birmingham, Glasgow), explicitly citing the bank’s refusal to sever ties with BAE and the F-35 supply chain.¹

4.2 The US Defense Primes: Boeing and Raytheon (RTX)

HSBC’s North American and global operations provide significant financing to the US primes that supply the bulk of the IDF’s heavy ordnance.

4.2.1 Boeing Defense, Space & Security

• IDF Platforms: F-15I “Ra’am” fighters, AH-64 Apache helicopters, JDAM (Joint Direct Attack Munition) tail kits.
• HSBC Exposure: HSBC is a lender in Boeing’s massive credit revolvers, which were drawn down heavily during Boeing’s production crises in 2024. The bank holds over $458 million in Boeing financial instruments.³
• Lethality: The Apache helicopter (Hellfire missiles) and JDAMs are the primary kinetic instruments used in the Gaza theater. HSBC-underwritten capital keeps Boeing’s production lines for these systems operational.²

4.2.2 RTX Corporation (formerly Raytheon)

• IDF Platforms: “Iron Dome” interceptors (Tamir missile partnership with Rafael), GBU-28 “Bunker Buster” bombs, Phalanx weapon systems for naval vessels (Sa’ar corvettes enforcing the naval blockade).
• HSBC Exposure: HSBC holds shares and underwrites debt for RTX. The “Deadly Investments” report linked HSBC financing directly to Raytheon during periods where its munitions were deployed in Gaza.¹²
• Structural Integration: Raytheon’s systems are integrated into the F-35 and F-16. Financing Raytheon supports the avionics and munitions layer of the IAF.⁴

Intelligence Verdict (CIR 4): HSBC is a Tier 1 Financier to the global defense supply chain. Its relationships with BAE, Boeing, and Raytheon are not peripheral; they are core banking relationships involving billions in committed capital. Through the “General Corporate Purposes” mechanism, HSBC provides the liquidity that enables these companies to fulfill IMOD contracts without restriction.

5. Dual-Use & Tactical Supply (CIR 2): The Caterpillar Case

This section addresses the supply of “dual-use” equipment—specifically heavy engineering machinery—that is ruggedized for combat. The primary subject is Caterpillar Inc. and its D9 bulldozer.

5.1 The D9R “Doobi” Weapon System

While Caterpillar markets the D9 as a civilian earthmoving machine, the units sold to the IMOD are procured specifically for conversion into the D9R armored bulldozer.

• Modifications: IAI adds slat armor (anti-RPG), bulletproof glass, and machine gun mounts.
• Operational Role: The D9 is the lead vehicle in ground assaults (clearing IEDs/mines) and the primary tool for punitive home demolitions in the West Bank. In the 2023-2024 Gaza ground invasion, D9s were used to raze entire neighborhoods to create buffer zones.²²

5.2 Forensic Review of HSBC’s Financing of Caterpillar

Despite the D9 being a clear symbol of the occupation infrastructure, HSBC maintains a robust and renewed financial partnership with Caterpillar.

5.2.1 The 2024-2025 Revolving Credit Facilities (RCFs)

Forensic review of SEC filings and corporate disclosures reveals HSBC’s ongoing participation in Caterpillar’s liquidity structures.

• August 2024 Facility: Caterpillar entered into a “Third Amended and Restated Credit Agreement” (5-Year Facility). HSBC is listed as a participating bank in the syndicate led by Citibank.⁶
• August 2025 Facility: Caterpillar renewed its “364-Day Facility” for $3.5 billion and a “Three-Year Facility.” HSBC remains a lender in these syndicates.
  • Terms: These are unsecured revolving credit facilities available for “general corporate purposes,” including working capital and support for commercial paper programs.⁷
  • Relevance: RCFs are the financial backbone of a manufacturing giant. They smooth out the volatility of cash flows. By participating, HSBC provides the assurance of liquidity that allows Caterpillar to maintain its global supply chain, including shipments to Israel via the US FMF program.

5.2.2 Bond Holdings and Investment

In addition to lending, HSBC funds hold significant equity and debt in Caterpillar.

• Holdings Value: Reports estimate HSBC’s investment exposure to Caterpillar at over $387 million.³
• Failure of Engagement: While some pension funds (e.g., KLP Norway) have divested from Caterpillar due to the risk of contributing to human rights violations in the West Bank, HSBC has resisted calls to divest. The bank likely relies on the argument that Caterpillar sells to the US government (FMF), which then transfers the equipment to Israel, thus removing direct contractual liability.²⁴

5.3 Other Dual-Use Financing: Volvo and CNH

HSBC also finances Volvo Group and CNH Industrial.

• Role in Occupation: Volvo excavators and loaders are frequently documented in the demolition of Bedouin villages in the Negev and Palestinian structures in Area C of the West Bank.
• Financial Link: HSBC is a top-tier lender to Volvo Group, participating in multi-billion dollar general credit facilities.¹⁰

Intelligence Verdict (CIR 2): HSBC provides Material Logistical Support to the tactical engineering corps of the IDF. The financing of Caterpillar is not “dual-use” in the benign sense; it is the financing of a supply chain that delivers the primary vehicle for habitat destruction in the OPT.

6. Logistical Sustainment (CIR 3): The Settlement Economy

This section audits HSBC’s financing of the “Occupation Industry”—companies that build, service, and maintain the illegal settlements. This addresses CIR 3 (Logistical Sustainment).

6.1 The “Don’t Buy Into Occupation” (DBIO) Findings

The DBIO coalition tracks financial flows from European institutions to companies listed in the UN Database of business enterprises involved in settlements.

• Aggregate Exposure: Between January 2021 and August 2024, European FIs provided $211 billion in lending and underwriting to settlement-linked companies.
• HSBC’s Ranking: HSBC consistently ranks as one of the top 5 European creditors to these entities, alongside BNP Paribas and Barclays. In previous reporting periods, HSBC’s lending volume to settlement companies exceeded $8.7 billion.⁸

6.2 Key Corporate Beneficiaries and Projects

The audit identifies specific Israeli and international firms financed by HSBC that are integral to the settlement enterprise.

6.2.1 Shapir Engineering and the Jerusalem Light Rail (JLR)

Target: Shapir Engineering and Industry Ltd.

Activity: Construction of the JLR (Red and Green Lines), which connects West Jerusalem to illegal settlements in East Jerusalem (Pisgat Ze’ev, Neve Ya’akov); operation of quarries in the West Bank (Natuf).

• HSBC Complicity:
  • Direct Financing: HSBC has acted as a financier and advisor for consortia involving Shapir.
  • Asset Management: HSBC Asset Management funds hold shares in Shapir Engineering (e.g., HSBC Holdings PLC listed as holding ~60,000 shares in some filings).²⁶
  • Advisory: Legal profiles indicate HSBC has worked on financing transactions involving Shapir’s partners (e.g., CAF of Spain) for the JLR project.²⁷
• Impact: The JLR is a strategic infrastructure project designed to cement the annexation of East Jerusalem. HSBC’s financing aids this geopolitical objective.¹⁰

6.2.2 Shikun & Binui

Target: Shikun & Binui Ltd.

Activity: Major real estate developer constructing housing units in West Bank settlements; infrastructure works in East Jerusalem.

• HSBC Complicity:
  • Investment: HSBC funds are listed as holding shares in Shikun & Binui. Voting records show HSBC Asset Management participating in AGMs.²⁹
  • Lending: HSBC is part of the banking pool available to Shikun & Binui for its general infrastructure projects.³¹

6.2.3 Solvay and Resource Extraction

Target: Solvay S.A. (Belgium)

Activity: Supply of chemicals and materials; linked to the “Bardala bypass” water pipeline project in the Jordan Valley, which diverts Palestinian water resources to settlements.

• HSBC Complicity: HSBC is a major lender to Solvay, participating in syndicated loans. The DBIO report attributes hundreds of millions in loan value to HSBC’s share of the Solvay syndicate.¹⁰
• Mechanism: This illustrates indirect complicity—financing a European parent company that executes projects supporting settlement viability.

6.2.4 Tourism and Real Estate Platforms

Targets: Airbnb, Booking Holdings, Expedia.

Activity: Listing rental properties in illegal settlements, thereby sustaining the settlement tourism economy.

• HSBC Complicity: HSBC acts as a corporate lender and bond underwriter for these tech giants. By providing general liquidity, HSBC supports their global platform operations, which include the contested listings.⁹

Table 1: HSBC Financial Links to Key Settlement Actors

Value indicates total syndicate size where HSBC is a lead participant.

Intelligence Verdict (CIR 3): HSBC is a Systemic Pillar of the Settlement Economy. Its financing is not limited to one sector; it spans transport (Shapir), housing (Shikun & Binui), and services (Airbnb). This broad-based financial support underwrites the economic viability of the occupation.

7. Operational Footprint and Direct Contracting (CIR 1)

This section addresses the physical presence of HSBC in Israel and its potential for direct contracting with state entities.

7.1 HSBC Israel Branch Operations

HSBC maintains a fully operational branch in Ramat Gan, Israel.

• Location: Amot Atrium Tower, 30th Floor, 2 Jabotinsky Street, Ramat Gan.³⁴
• SWIFT Code: HSBCILITXXX.³⁶
• Business Model: The branch explicitly excludes retail banking (consumer mortgages, credit cards). Its focus is Commercial Banking and Global Private Banking.³⁷
• Strategic Function: The branch serves as a conduit for Israeli corporations to access global capital markets. It provides:
  • Trade Finance: Letters of credit and guarantees for importers/exporters.
  • Foreign Exchange (FX): Managing currency risk for Israeli tech and defense firms trading in USD/GBP.
  • Syndicated Lending: Organizing loans for major Israeli conglomerates (e.g., Delek Group, Israel Chemicals).

7.2 Connection to State Contracting

While there is no public evidence of HSBC Israel directly signing contracts with the IMOD for weapons procurement (a role typically held by US banks managing FMF funds or Israeli banks like Leumi/Hapoalim), the branch finances the contractors.

• Intermediary Role: By providing trade finance to a company like Elbit or IAI, HSBC facilitates the import of components required for IMOD contracts.
• Tech Sector Integration: HSBC markets itself as a partner to the “Startup Nation.” Given the deep integration of the Israeli tech sector with the military (Unit 8200 alumni founding cyber firms), HSBC’s financing of tech firms (e.g., Motorola Solutions Israel, HPE) often bleeds into defense support. Motorola provides the “MotoEagle” surveillance system for settlements and the Separation Wall; HSBC finances Motorola Solutions globally.⁹

Intelligence Verdict (CIR 1): HSBC’s operational footprint is Commercial and Enabler-Focused. It avoids the optics of direct military contracting but provides the essential banking infrastructure (FX, Trade Finance) that allows the Israeli defense and technology sectors to operate globally.

8. Policy Analysis: The Failure of Internal Controls

This section analyzes why HSBC’s internal governance failed to prevent the complicity detailed above.

8.1 The “Defence Equipment Sector Policy”

HSBC’s policy is publicly stated to restrict financing for:

1. Production or sale of cluster munitions and antipersonnel mines.
2. Customers who “solely or primarily” manufacture weapons.¹¹

8.1.1 The “Solely or Primarily” Loophole

This is the critical failure point.

• Mechanism: HSBC defines “primarily” usually as >50% of revenue.
• Application: Companies like Boeing, Airbus, and Rolls-Royce are huge civil aerospace manufacturers. Their defense divisions, while generating billions, may only be 30-40% of total revenue.
• Result: They are classified as “Civil Aerospace” or “Industrial” clients. This allows HSBC to lend them unlimited capital for “General Corporate Purposes,” which the company can then allocate internally to its defense division. This explains the continued financing of Boeing (Apache/JDAM) and Caterpillar (D9).¹¹

8.1.2 The “Passive” Asset Management Defense

HSBC frequently argues that shareholdings in Elbit or BAE are “passive” and held “on behalf of clients.”

• Flaw: As detailed in Section 3.2.2, index inclusion is a choice. Ethical indices exist. By utilizing standard indices for its funds, HSBC chooses to direct capital to defense firms. Furthermore, earning fees from custodial services for these shares constitutes profiting from the defense sector.³⁹

8.1.3 Lack of “Occupied Territory” Screening

Unlike some Nordic banks (e.g., Danske Bank, KLP), HSBC does not appear to have a specific policy excluding companies based solely on their operations in the OPT. This allows the bank to finance Shapir Engineering and Solvay, as their activities (railways, water pipes) are not “weapons,” even though they are integral to the illegal settlement enterprise.⁸

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