Agoda - Military Audit

Direct Defence Contracting & Procurement

Agoda and its ultimate parent, Booking Holdings Inc. (NASDAQ: BKNG), do not appear in Booking Holdings’ proxy statements or 10-K filings as a counterparty to any Israeli Ministry of Defense, IDF, Israel Prison Service, or Israel Border Police contract, tender, or memorandum of understanding ¹²³. No public evidence identified of Agoda appearing in SIBAT defence-export directories or defence exhibition catalogues.

Dual-Use Products & Tactical Variants

Agoda operates a consumer- and B2B-facing online travel booking platform (OTA); this product category has no ruggedised, tactical, or military-specification variant ⁴. No public evidence identified of export licence applications or end-user certificates tied to Israeli security-force sales of Agoda’s platform or services.

Heavy Machinery, Construction & Infrastructure

Agoda’s business is software- and platform-based, with no machinery, vehicle, or construction-equipment manufacturing or distribution activity ⁴. No public evidence identified of Agoda-branded equipment, vehicles, or machinery present in the West Bank, East Jerusalem, or Golan Heights. Civil-society documentation of the sector’s settlement footprint concerns property listings by the parent brand Booking.com rather than construction or demolition equipment, placing this outside heavy-machinery scope ⁵⁶.

Supply Chain Integration with Defence Primes

A June 2024 PAX Netherlands report on companies arming Israel and their financiers, reviewed in full, does not name Agoda or Booking Holdings among manufacturers, financiers, or supply-chain participants ⁷. No public evidence identified of any component, subsystem, or manufacturing-services relationship between Agoda/Booking Holdings and Elbit Systems, Israel Aerospace Industries, Rafael Advanced Defense Systems, or Israel Military Industries/Elbit Land. No public evidence identified of joint development, co-production, or technology-transfer agreements between Agoda and Israeli defence firms.

Logistical Sustainment & Base Services

No public evidence identified of Agoda providing catering, transport, fuel, facilities-maintenance, or telecommunications services to IDF bases, training facilities, or detention centres. No public evidence identified of shipping, freight, or port-handling contracts servicing Israeli military cargo linked to Agoda or Booking Holdings.

Munitions, Weapons Systems & Strategic Platforms

No public evidence identified of Agoda involvement in lethal-systems manufacturing, munitions or precursor-material supply, or strategic platforms such as Iron Dome, David’s Sling, or Arrow interceptor systems. No public evidence identified of Agoda supplying sub-systems or critical components to any Israeli weapons program.

Export Licensing, Regulatory & Legal History

No public evidence identified of any export-licence grant, denial, suspension, or revocation decision involving Agoda in any jurisdiction, consistent with Agoda’s platform not handling defence-controlled goods. At the parent-brand level, a criminal complaint was filed with the Dutch Public Prosecution Service by the European Legal Support Center, Al-Haq, SOMO, and The Rights Forum alleging that Booking.com’s revenue from Israeli settlement property listings constitutes “proceeds of crime” under Dutch law, carrying potential penalties of up to 20% of the company’s prior-year net revenue ⁸. On 16 October 2025, the Ligue des droits de l’Homme filed a lawsuit in France against Airbnb and Booking.com alleging complicity in “aggravated concealment of war crimes” through settlement-property listings, characterised in reporting as “occupation tourism” ⁹¹⁰; a related case was reported to have a preliminary hearing scheduled for 13 January ¹⁰. Booking Holdings’ FY2026 proxy statement includes Proposal 6, a shareholder resolution requesting board-level disclosure of human-rights-risk oversight tied to Israeli settlement operations, which the board recommended shareholders reject, describing the settlement-related business as “financially insignificant” ¹¹¹². The JLens Network separately published an analysis urging shareholders to vote against Proposal 6 ¹¹. These regulatory and legal matters concern settlement property listings under the Booking.com brand rather than defence trade, arms embargoes, or military export controls, and are noted here for completeness rather than as direct-military evidence.

Civil Society Scrutiny & Documented Investigations

Agoda itself is not separately named in the principal civil-society and monitoring sources reviewed - Who Profits, AFSC Investigate, Amnesty International’s 2019 tourism-sector report, or OHCHR settlement-business database coverage - all of which attach findings to the parent brand Booking.com / Booking Holdings Inc. rather than to Agoda ⁵⁶¹²⁴. Who Profits, with data current through 30 November 2024, documents Booking.com listing 24 properties across 12 West Bank settlements, 7 listings in East Jerusalem settlements, and 152 listings across 28 Golan Heights settlements, operated through an Israeli subsidiary, Israel Online Hotel Reservations Ltd ⁵. AFSC Investigate corroborates 19 West Bank/East Jerusalem settlement listings and 25 Golan settlement listings as of 2022, and describes the Israeli subsidiary as conducting in-person visits, training, and verification with settlement property operators, raising “pillage” concerns under occupation law ⁶. Amnesty International’s January 2019 “Destination: Occupation” report found Booking.com listed 45 hotels and rentals in West Bank/OPT settlements, alongside Airbnb (300+ listings) and TripAdvisor (70+ listings) ¹²¹³¹⁴. Booking.com changed settlement-location labels from “Israel” to “Palestinian Territory, Israeli Settlement” in 2018, and in 2022 added a “conflict-affected area” safety warning to West Bank listings following investor pressure, without using the term “occupied,” reportedly due to Israeli government pressure ¹⁵¹⁶. The UN Human Rights Office’s September 2025 update to its settlement-business database expanded coverage to 158 entities, though this audit could not confirm from available reporting whether Booking Holdings is named in the current iteration ¹⁷¹⁸¹⁹. Harvard University’s endowment was reported in March 2020 to hold approximately $200 million in UN-listed settlement-tied companies including Booking Holdings, and was reported in January 2025 to have reinvested approximately $150 million in Booking Holdings ²⁰²¹. The Business & Human Rights Resource Centre has separately compiled reporting on Booking.com’s settlement-related human rights impact, including company comments ²². No public evidence identified of civil-society investigations tying Agoda or Booking Holdings to military or security-force procurement; all identified scrutiny concerns settlement tourism and property-listing conduct rather than defence-related activity.

Agoda’s chief executive officer since 1 July 2022, Omri Morgenshtern, is an Israeli national and a graduate of the IDF’s Talpiot program, an elite decade-long service track for top science and engineering recruits used to develop advanced military research and weapons capability ²³²⁴²⁵. Retrieved sources document his post-service civilian career - co-founding Qlika in 2012, its acquisition by Priceline/Booking Holdings in 2014, and his subsequent rise through Agoda’s product, COO, and CEO roles - but no source documents any post-military-service defence-industry directorship, equity stake in an Israeli defence prime, reservist-fund donation, or public co-belligerency statement by Morgenshtern ²³²⁵. One Booking Holdings director identified in available bio data, James M. Guyette, held a defence-adjacent executive role as Chairman/President/CEO of Rolls-Royce North America Inc. (1997–2015), a supplier to global aerospace, defence, marine, and energy markets, though this is a general aerospace-industry background rather than an Israeli defence-sector tie. No public evidence identified of other Booking Holdings or Agoda directors, executives, or major shareholders holding Israeli defence-industry directorships, settlement-organisation affiliations, or FIDF donations.