Agoda

Key Findings

• Economic: Booking.com’s documented settlement-property commerce is attributed to Agoda under the rubric’s integrated-group rule. The 2025 UN report records continuing Booking.com profit from settlement listings; group filings and Agoda partner materials document operational and financial integration.^{1, 2, 3}
• Digital: Agoda’s broad Wiz deployment supports the Soft Dual-Use Procurement assessment. The record does not verify that Agoda data is hosted in, processed in, or accessed from Israel.^{4, 5}
• Political: Continuing settlement listings support the group-attributed settlement-normalisation assessment. The documented operator is Booking.com; the sources do not establish Agoda-specific settlement inventory.^{6, 1, 2}
• Not found: No public evidence identified of Agoda or Booking Holdings supplying Israeli military or security bodies, operating military technology, or holding defence-procurement contracts.^{7, 8}

Target Profile

Key Facts:

• Agoda was founded in 2005 and acquired by Priceline, now Booking Holdings, in 2007.¹³
• Priceline acquired Israeli ad-tech startup Qlika in March 2014 for a contemporaneously reported $15–20 million; Qlika’s founders subsequently joined Agoda.^{12, 14}
• Publicly available group reporting lists Agoda International Israel Ltd. among Israeli Booking Holdings entities, but does not establish its current technical remit, data access, or headcount.¹⁵

Executive Summary

Agoda is a Singapore-headquartered online travel platform and a consumer-facing brand of Booking Holdings. The governing economic and political findings concern Booking.com’s continuing settlement-property commerce and normalisation, attributed under the rubric’s integrated-group rule. The UN Special Rapporteur’s July 2025 report names Booking Holdings and Booking.com and records continuing Booking.com profit from settlement listings. This does not establish listings on Agoda’s own interface.^{9, 2, 1} Agoda also has a documented Wiz cloud-security relationship, a historical Qlika acquisition link and an Israeli service entity.^{12, 15, 4}

The historical Israeli operating-footprint evidence concerns the Qlika acquisition and corporate presence. Historical reporting describes the acquired team as supporting pricing, bidding, anomaly detection and related platform work. However, the FY2023 entity-specific primary record classifies Agoda International Israel Ltd. as providing “Administrative, Management or Support Services,” not research and development. The supplied record therefore does not establish current Israeli control of Agoda’s production systems, algorithms, customer-data stores, model training, or deployment approvals.^{12, 15}

Agoda is also a verified Wiz customer. Wiz’s case study describes cloud-security, asset-inventory and vulnerability-management uses across Agoda environments. Wiz’s general subprocessor materials identify Wiz Cloud Ltd. in Israel as an affiliate capable of technical-support, service-management and maintenance functions, and state that customer personal data may be processed. Those materials do not identify Agoda’s hosting region, the data supplied to Wiz, whether Israeli personnel accessed Agoda data, or whether any Agoda data was processed in Israel.^{4, 5}

Settlement-related evidence requires careful entity attribution. Who Profits, AFSC Investigate, the OHCHR database and the UN Special Rapporteur’s 2025 report attribute identified settlement tourism listings to Booking.com and/or Booking Holdings, not Agoda-specific properties.^{6, 16, 17, 1} Agoda’s terms state that certain bookings may be facilitated by Booking.com and other group partners, and Agoda materials document shared advertising infrastructure.³ Alongside the SEC filing’s shared resources, technology, co-development and consolidated financing, these links support the rubric’s unitary-group attribution and direct proximity. They do not prove a settlement-property feed or Agoda display of a particular settlement property.^{18, 19, 2, 3}

No public evidence identified of Agoda or Booking Holdings providing products or services to Israeli military, intelligence, police, prison or border-security bodies; supplying weapons, dual-use systems or military logistics; participating in Project Nimbus; or operating Agoda technology for surveillance or military purposes.^{7, 8, 20} On the fixed, human-vetted V6.5 record, the result is a BRS of 592, placing Agoda in Tier C (Substantial Complicity). This classification is governed by group-attributed settlement commerce and normalisation, with a separate digital procurement contribution. The historical acquisition and Israeli service footprint are non-governing findings; neither unverified data exposure nor executive nationality supplies the scoring rationale.

Timeline of Relevant Events

Corporate Overview

Agoda is an Asia-Pacific-focused travel-reservation business offering accommodation reservations as well as flights, ground transportation and attractions. Booking Holdings identifies Agoda alongside Booking.com, Priceline, KAYAK and OpenTable as separate consumer-facing brands. Agoda Company Pte. Ltd. in Singapore and Agoda Holding Company Limited in Mauritius are identified as wholly owned Booking Holdings subsidiaries.^{9, 2}

The group’s filings describe distinct brand strategies and historical operational independence, alongside increasing collaboration, shared resources, technological innovation and co-developed services. Consolidated financial reporting eliminates intercompany transactions; it does not identify Agoda-specific funding arrangements, an Agoda–Booking.com inventory percentage, or property-level cross-brand mapping.²

The documentary record reports Agoda International Israel Ltd. as an Israeli private company, incorporated in 2015 and registered in Ramat Gan. The underlying registry-mirror evidence is not a direct Israeli Registrar extract and does not establish a complete ownership chain or share percentage. Booking Holdings’ 2023 country-by-country reporting places the entity in the “Administrative, Management or Support Services” category; it does not verify current R&D, staff functions, operational control, or standalone headcount.^{15, 22}

Agoda’s terms state that some reservations may be facilitated by Booking Holdings, KAYAK, Priceline or Booking.com, with partner terms governing and Agoda potentially receiving a fee or commission. Agoda’s supplier disclosures also name Booking.com as a third-party accommodation supplier. These are documented transactional and data-transfer links, but they do not establish shared settlement inventory or that Booking.com’s documented settlement listings appeared on Agoda.^{18, 19}

Domain Summaries

Military: Military

Mechanism of Involvement

No public evidence identified of Agoda or Booking Holdings contracts, tenders or memoranda with the Israeli Ministry of Defence, IDF, intelligence agencies, police, prison service or border police.^{7, 8} No public evidence identified of weapons, munitions, tactical products, military logistics, defence-prime supply-chain relationships, export licences, military base services, or Israeli security-force use of Agoda’s travel-platform technology.^{7, 8}

The reviewed PAX Netherlands report on companies arming Israel and their financiers does not name Agoda or Booking Holdings.²⁶ Agoda’s product is a civilian consumer and B2B travel-booking platform; the audits identified no tactical or military-specification variant.¹³

Counter-Arguments and Evidence Limits

The strongest defence is direct: Agoda’s identified activity is civilian travel intermediation, not defence production or state-security provision. The record found no public military procurement, defence-export, military logistics, or weapons-system evidence. Legal and civil-society scrutiny discussed elsewhere in this dossier concerns Booking.com settlement listings, not arms trade or military export controls.^{7, 8, 23}

Absence findings are document-scoped: they do not prove that undisclosed private arrangements cannot exist. They do establish that no public evidence was identified in the audited sources.

Named Entities and Evidence Map

• Agoda / Booking Holdings: No public evidence identified of Israeli defence or security procurement.^{7, 8}
• PAX Netherlands: Its June 2024 report did not name Agoda or Booking Holdings among companies arming Israel or financiers.²⁶
• Booking.com: Settlement-listing allegations and proceedings concern this sibling brand, not a military relationship.^{23, 1}

Digital: Digital

Mechanism of Involvement

Agoda is a verified Wiz customer. Wiz’s published case study states that Agoda uses Wiz Cloud CSPM across AWS, Google Cloud, on-premises and hybrid-cloud environments for cloud visibility, inventory, risk prioritisation, remediation and compliance support.⁴ Wiz’s general subprocessor list identifies Wiz Cloud Ltd. in Israel as an affiliate providing technical support, service management and maintenance, and says Wiz services may process customer personal data.⁵

The records establish a potential Israeli-affiliate processing or access pathway in Wiz’s service architecture, but do not verify actual Agoda data exposure to Israel. Agoda’s privacy materials describe international transfers but do not identify Israel as a storage, routing, processing or access location.^{5, 27}

Historical reporting links the Tel Aviv operation to data science and pricing after Qlika’s acquisition. Current primary reporting does not establish that Agoda International Israel Ltd. controls pricing, bidding, anomaly detection, customer-data stores, model training or production deployment; the entity is classified as administrative, management or support services.^{12, 15}

Counter-Arguments and Evidence Limits

The strongest defence is that the documented Wiz relationship is a civilian cloud-security vendor relationship, not a security-state contract. No public evidence identified of Agoda technology being supplied to Israeli military, intelligence, police or other security bodies; of Project Nimbus participation; of surveillance, biometric, offensive-cyber or military AI systems; or of Israeli data residency for Agoda customer information.^{5, 8, 20, 27}

Neither Wiz’s generic subprocessor disclosure nor historical Tel Aviv R&D reporting confirms Agoda data processing in Israel or a present Israeli engineering mandate. The documented evidence supports a potential pathway, not verified data access or Israeli operational control. The scored act is the separately verified broad Wiz procurement, which fits the rubric’s Soft Dual-Use Procurement band without requiring a security-state customer or actual Israeli data access.⁴

Named Entities and Evidence Map

• Wiz: Documented Agoda cloud-security supplier.⁴
• Wiz Cloud Ltd.: Israeli affiliate listed in Wiz’s general subprocessor materials.⁵
• Agoda International Israel Ltd.: Group entity classified in the 2023 country report as administrative, management or support services.¹⁵
• Qlika: Israeli startup acquired by Priceline in 2014; its team joined Agoda-related operations.^{12, 14}

Economic: Economic

Mechanism of Involvement

The governing economic finding is group-attributed settlement commerce. Who Profits documents Booking.com settlement listings across several occupied territories, and the July 2025 UN report records continuing profit from those listings. Shared group operations and financing support unitary attribution under the rubric, while Booking.com remains the identified operator.^{6, 1, 2, 3}

The historical economic record also includes Priceline’s 2014 acquisition of Qlika for a contemporaneously reported $15–20 million, followed by an Israeli operating presence.^{12, 14} Agoda International Israel Ltd. is reported as incorporated in 2015 in Ramat Gan. The current record supports its existence and group association, but not a complete ownership chain, current headcount, local revenue, tax paid, payroll, capital expenditure or R&D expenditure.^{15, 22}

Agoda itself is a travel intermediary, not a physical-goods manufacturer or distributor; no public evidence identified of conventional Israeli physical sourcing, import arrangements or settlement-origin goods trade.¹³ Agoda’s group-level integration includes partner facilitation, shared advertising products and data/supplier links with Booking.com; the audits do not establish Agoda-specific settlement transactions or inventory.^{18, 19, 3}

Booking Holdings’ country-by-country report gives aggregated Israel-jurisdiction figures, including revenue, profit and tax amounts, but covers four entities and cannot be attributed to Agoda International Israel Ltd.¹⁵ Group-level Israel-related travel observations likewise cannot be treated as Agoda-specific market figures.²⁸

Counter-Arguments and Evidence Limits

Agoda’s strongest defence is that its Israeli presence is limited in the audited record and that the Qlika transaction is historical. The FY2023 entity-level classification is administrative, management or support services, not R&D. No public evidence identified of Agoda factories, data centres, logistics hubs, Israeli sovereign-debt activity, direct state contracts, defence contracts, critical-infrastructure status, or a dominant Israeli market position.^{15, 2, 22}

The settlement-listing evidence names Booking.com, a separate brand. That limits claims about Agoda inventory, but does not displace the rubric’s integrated-group attribution where operational and financial integration is documented. The reviewed record establishes no durable Booking.com exit; dated listing counts are not presented as a September 2026 live inventory.^{6, 1, 2, 3}

Named Entities and Evidence Map

• Qlika: Israeli ad-tech company acquired by Priceline in 2014.^{12, 14}
• Agoda International Israel Ltd.: Reported Israeli company; current group classification is administrative, management or support services.^{15, 22}
• Booking.com: Separate sibling brand with the documented settlement-tourism footprint.^{6, 16}
• Booking Holdings: Common parent; group reporting aggregates Israel-jurisdiction figures and group operations.^{15, 2}

Political: Political

Mechanism of Involvement

The political and settlement-related nexus is primarily group-level. Booking Holdings and Booking.com are named in the OHCHR settlement-business database and the UN Special Rapporteur’s 2025 report; the cited underlying listing activity is attributed to Booking.com rather than Agoda.^{16, 1} Who Profits and AFSC Investigate document Booking.com listings in West Bank, East Jerusalem and Golan Heights settlements across the cited reporting periods.^{6, 17} The July 2025 UN report’s continuation finding supports treatment as sustained public normalisation after the July 2024 notice point. The separate 2022 reversal of occupation-specific warning language is a lower governing frame and does not mitigate the continuing listings.^{1, 29}

A coalition filed a criminal complaint against Booking.com B.V. in the Netherlands alleging money laundering of proceeds connected to settlement rentals. The Dutch Prosecutor indicated an intention to investigate, and the coalition later reported an Article 12 procedure concerning alleged inaction. These are unresolved allegations and procedural developments, not findings of liability.^{23, 30}

Booking Holdings’ 2026 proxy states that the group assesses human-rights risks related to listings in conflict-affected areas and permits listings unless legally prohibited. The proxy includes a shareholder proposal seeking additional disclosure on human-rights-risk oversight connected to Israeli settlement operations; the Board recommended rejection and described the settlement-related business as financially insignificant.^{25, 31}

Counter-Arguments and Evidence Limits

Entity specificity remains a factual limit: Agoda and Booking.com are separate consumer-facing brands, and shared services do not prove that Agoda carried a particular settlement property. The score applies the rubric’s group rule on the separately evidenced operational and financial integration, rather than claiming an Agoda-specific listing act.^{18, 19, 2, 3}

No public evidence identified of an Agoda-branded statement on Israel/Palestine or Gaza, Agoda-specific settlement-listing policy, direct political donations to pro-Israel or settlement-linked organisations, Israel-Palestine-specific lobbying, or provision of free services to Israeli military or state bodies.^{20, 32} The complaint against Booking.com is contested and unresolved; Booking.com has reportedly maintained that it complies with applicable law and that no applicable law prohibits listing accommodation in settlements.³³

Named Entities and Evidence Map

• Booking.com / Booking Holdings: Named in the cited settlement-business and UN Special Rapporteur materials.^{16, 1}
• Agoda: No public evidence identified in the reviewed authoritative record of Agoda-specific settlement inventory.^{6, 16, 1}
• European Legal Support Center, Al-Haq, SOMO and The Rights Forum: Complainant coalition in the Dutch matter against Booking.com B.V.²³
• Booking Holdings Board: 2026 proxy position and shareholder-resolution disclosure.^{25, 31}

BDS-1000 Score

Method: V6.5.

• V_MAX: 6.50 Avg_OTHERS: 3.03
• BRS Score: 592 Tier: C (Substantial Complicity)

V_MAX is POL 6.50. The settlement nexus sets I=6.5 in ECON and POL; multi-year, multi-settlement commerce supports ECON M=6.5, while sustained public normalisation supports POL M=7.0. Operational and financial integration supports unitary-group P=9.1 in both domains. DIG 3.05 reflects broad, directly procured Wiz cloud security at I/M/P 3.5/6.1/9.1, without scoring the unverified data-access pathway. MIL remains zero on searched public evidence. The 2014 acquisition and Israeli service entity do not govern the final economic score.^{4, 6, 1, 2, 3}

Methodology Note

• Evidence is limited to the four supplied domain audits and their cited documentary record; claims not established there are excluded or qualified.
• Impact assesses the activity type, M assesses scale, and P assesses directness. Scores are not assertions of legal liability.
• Entity attribution is explicit: Booking.com is the documented settlement-listing operator. The canonical integrated-group doctrine attributes that conduct to Agoda based on operational and financial integration; it does not establish Agoda-specific inventory or legal liability.
• A verified durable exit could reduce the present relationship. The reviewed record establishes no durable Booking.com settlement-listing exit; the separately documented 2022 retreat from occupation-specific warning language earns no mitigation.^{1, 29}
• Settlement operation may bear on both Economic and Political where the evidence supports both economic activity and political/occupation-related exposure; this does not erase the distinction between Agoda and Booking.com.
• “No public evidence identified” reports the result of the audits’ documented checks. It is not a claim that undisclosed conduct is impossible.