Bank of America

Key Findings

• Economic: BofA Securities held $4.2 billion in contractual underwriting allocations across three Israeli sovereign offerings totaling $19 billion in 2024–2026. These allocations establish primary-market financing participation, not permanent bond ownership or earmarked military expenditure.^{1, 2, 3}
• Economic: BofA Securities represented the underwriters in Elbit Systems’ May 2025 equity offering, which raised approximately $588.8 million gross after full exercise of the additional-share option. Elbit specified general corporate purposes; no particular weapons programme was identified as the recipient.^{4, 5, 6}
• Political: Senior executive Bernard Mensah publicly discussed Israel’s commercial prospects in August 2023. The audited record establishes attributable business commentary, but no subsequent corporate adoption of those remarks as a political campaign or independent political endorsement within the reviewed sovereign-underwriting documents.^{2, 3, 7, 8}
• Not found: No public evidence identified of direct Bank of America Israeli military procurement, weapons manufacture, military-targeting software, or technology provision to Israeli military or intelligence agencies. The documented technology relationships concern civilian banking functions.^{9, 10, 11}

Target Profile

Executive Summary

Bank of America’s strongest documented Israel/Palestine nexus is financial intermediation. Its group entity BofA Securities entered Israeli sovereign-underwriting agreements in March 2024, February 2025 and January 2026, receiving contractual allocations of $2 billion, $1 billion and $1.2 billion respectively. Together, these represent $4.2 billion of underwriting commitments across $19 billion of issuance. They establish recurring participation in Israel’s access to international capital markets; they do not establish the bank’s eventual retained holdings, net credit exposure or the destination of particular proceeds within government expenditure.^{1, 2, 3}

Corporate transactions extend this record. BofA Securities represented the syndicate underwriting Elbit Systems’ May 2025 equity offering, which closed with approximately $588.8 million in gross proceeds. The offering directly supported an Israeli defence manufacturer, but the disclosed purpose was general corporate funding rather than an identified weapons system. Separate records establish Teva credit-administration and bond-underwriting relationships. A December 2024 CyberArk transaction was materially different: BofA Securities underwrote a secondary shareholder sale, and CyberArk expressly received no proceeds.^{4, 5, 6, 17, 18, 19, 20}

The political record is narrower than the financing record. Mensah’s August 2023 interview promoted commercial prospects and described the importance of the bank’s Israeli presence to its international strategy. A November 2023 secondary report described an internal statement concerning the 7 October attacks and employee objections concerning Palestinian suffering. Neither record establishes a continuing institutional political campaign. The reviewed 2025–2026 underwriting documents establish commercial securities distribution, without independently attributable endorsement of Israeli government policy.^{7, 8, 21, 2, 3}

The audits identified no direct Israeli military procurement, weapons manufacture, operational military services, military digital infrastructure, settlement facilities or verified military-directed corporate donations. Current CyberArk and NICE technology use concerns banking security and communications recording. UN experts raised concerns about reported investments in RTX and Lockheed Martin, but their communication is not a judicial determination. A reported reduction exceeding 50% in disclosed Elbit holdings must also remain in the record, without being treated as proof of complete withdrawal.^{9, 10, 11, 22, 23}

The fixed, human-vetted V6.5 result is BRS 743, Tier B (Severe Complicity). Economic activity supplies the dominant domain score; the political score is substantially lower, and military and digital scores remain zero. This is the corpus’s evidentiary classification, not a finding of legal liability.

Timeline of Relevant Events

Corporate Overview

Bank of America’s affiliate disclosures identify Bank of America Corporation, Bank of America, N.A., BofA Securities and Merrill entities within the same corporate family. The relevant activities must nevertheless be attributed to the entity performing them: BofA Securities executed the securities-underwriting agreements, while Bank of America, N.A. acted as administrative agent in the cited Teva credit arrangement.^{29, 1, 2, 3, 17}

The Israeli operating connection is documented through Merrill Lynch Israel Ltd., identified as Israeli-incorporated and located in Tel Aviv in the group’s 2023 and 2024 subsidiary exhibits. The current international directory separately lists an office at 1 Azrieli Center, Round Tower, 35th Floor, Tel Aviv. These establish a local financial-services presence; they do not establish a manufacturing operation, retail-bank network or technology-development campus.^{30, 15, 16}

The historical Merrill Lynch acquisition provides structural context, while later subsidiary disclosures establish continuity beyond that acquisition. The audits did not establish the Israeli subsidiary’s exact equity percentage, stand-alone acquisition price, revenue, employee count, tax payments or profit repatriation. No public evidence identified of Israeli controlling ownership, a state golden share or an Israeli-government mandate governing Bank of America.^{12, 24, 30, 15}

No public evidence identified of Bank of America acquiring controlling operating ownership of Teva, ZIM or an Israeli defence manufacturer. The audited proposed ZIM acquisition concerned Hapag-Lloyd, with arrangements involving FIMI and Israeli state special rights; it must not be recast as a Bank of America acquisition.³¹

Domain Summaries

Military: Military

Mechanism of Involvement

The strongest defence-sector transaction is financial rather than operational. On 21 May 2025, BofA Securities entered Elbit Systems’ equity-underwriting agreement as representative of four underwriters. Its initial allocation was 477,908 shares, approximately 35% of the initial offering: $179,215,500 at the $375 public offering price, or approximately $175.7 million at the contractual underwriter purchase price.⁵

Elbit confirmed full exercise of the additional-share option and closing on 23 May. Aggregate gross proceeds were $588,850,125. Applying BofA’s initial proportion to the option implies an indicative total allocation of approximately 549,594 shares, worth approximately $206.1 million at the public offering price. That expanded allocation is calculated, not separately confirmed as BofA’s final executed allocation.^{4, 5}

The May 2024 UN communication also raised concerns about reported investments in RTX and Lockheed Martin and the adequacy of heightened human-rights due diligence. It did not identify a bank-specific financing contract restricted to an Israeli weapons system.²²

Counter-Arguments and Evidence Limits

The company’s strongest defence is the distinction between financial services and military supply. No public evidence identified of direct Israeli defence procurement awards, weapons manufacture, component supply, military logistics, base services or purpose-built targeting software. Elbit’s disclosed use of proceeds was general corporate purposes, with broad management discretion; an earmarked Israeli procurement programme was not identified.^{6, 9}

Sovereign underwriting likewise does not establish an identified military purchase. UN concerns are allegations and requests for explanation, not adjudicated findings. The supplied audit identified no final judicial determination establishing Bank of America’s responsibility for a specific Israeli weapons transfer.^{1, 2, 3, 22}

The reported Elbit shareholding reduction is mitigating evidence, although not proof of complete divestment. Conversely, subsequent underwriting is a distinct transaction and does not establish that earlier portfolio reductions were fictitious.^{23, 4, 5}

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The verified relationships concern internal banking technology. A 2026 recruitment advertisement identifies CyberArk and HashiCorp Vault within the bank’s privileged-access-management programme. A separate Singapore advertisement requires NICE voice-recording experience for communications engineering, maintenance and migration work. Contract values, licence counts and hosting geography are undisclosed.^{10, 11}

Verint’s 2017 OpinionLab account documents customer-feedback analysis and support workflows. This is historical civilian customer-experience activity; continuation under the same product or contractual arrangements in 2026 is unconfirmed.²⁵

The bank’s CashPro privacy notice permits international processing where it maintains facilities or service providers. It does not identify an Israeli data centre, particular Israeli processor or customer dataset transferred to Israel.³³

Counter-Arguments and Evidence Limits

No public evidence identified of Bank of America supplying cloud infrastructure, cybersecurity platforms, surveillance systems or AI to Israeli military or intelligence agencies. No public evidence identified of Project Nimbus participation, an Israeli data centre, settlement digital infrastructure, Palestinian surveillance training datasets or military-targeting software.

Civilian procurement from a technology supplier does not establish deployment by Israeli security bodies. The recruitment advertisements support internal operational use only.^{10, 11}

Secondary databases report historical NICE deployment in 2018 and Verint EdgeVMS use for banking-location video review. Those records lack procurement-level confirmation, and the Verint deployment’s current status is unknown. A SentinelOne article mentioning Bank of America as an insider-threat example establishes no customer relationship.^{34, 35, 36}

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

Recurring sovereign underwriting is the principal economic mechanism. BofA Securities accepted $2 billion in contractual allocations in March 2024, $1 billion in February 2025 and $1.2 billion in January 2026. These executed agreements establish direct participation in financing and distributing Israeli sovereign obligations.^{1, 2, 3}

BankTrack, PAX and Profundo identified Bank of America among seven sovereign-debt underwriters in research published in February 2025. Their characterisation of issuance as supporting war expenditure is attributable to the researchers. The contracts independently establish the sovereign borrower and allocations, without specifying departmental or weapons-programme expenditure.^{37, 1, 2}

Corporate relationships broaden the documented activity. Teva’s May 2024 credit amendment identifies Bank of America, N.A. as administrative agent, and its May 2025 bond transaction identifies BofA Securities as an active joint book-running manager. These are corporate banking and capital-markets functions, not evidence of control over Teva.^{17, 18}

The CyberArk transaction requires particular care. BofA Securities was sole underwriter for 1,142,538 existing shares sold by Triton Seller, LP at a contractual purchase price of $324.46 per share. The resulting approximately $370.7 million was consideration for the shareholder’s disposal before expenses. CyberArk received no proceeds; permanent BofA ownership and realised underwriting profit were not established.^{19, 20}

Merrill Lynch Israel Ltd. and the Tel Aviv office provide an operating nexus alongside these transactions. Their presence does not quantify Israeli revenue, tax contribution, employment expenditure or local profit.^{30, 15, 16}

Counter-Arguments and Evidence Limits

Underwriting commitments are neither donations nor verified long-term investments. The $4.2 billion aggregate must not be described as retained Israeli sovereign holdings, a net lending balance or money earmarked for military operations. The audits did not establish underwriting fees or final investor positions.^{1, 2, 3}

The civilian nature of Teva’s pharmaceutical financing and the secondary nature of CyberArk’s sale also limit broader claims. Financing relationships establish services to counterparties, not ownership of their operations or responsibility for all their conduct.^{17, 18, 19, 20}

No public evidence identified of settlement-specific lending, a settlement-backed security, settlement premises, settlement-origin consumer-goods trade, an Israeli manufacturing plant or verified annual Israeli tax and revenue totals. The Tel Aviv location must not be presented as a settlement operation.¹⁶

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

Mensah’s August 2023 Globes interview is the clearest attributable senior-executive communication. His official biography establishes responsibility for international strategy, and the interview links Israel’s commercial prospects to that remit. The external channel was an Israeli business newspaper; the remarks addressed technology, human capital, research investment and access to US markets.^{7, 8}

The bank’s official location directory combines its Israel listing with global promotional language offering institutional financial services. This establishes current commercial presentation as of the audit cut-off. The language is global and does not independently endorse Israeli government policies; no dated revision history established uninterrupted use of its exact wording.¹⁶

November 2023 reporting described an internal statement condemning the attacks in Israel and employee objections concerning Palestinian suffering. This remains a secondary account. Separately, the awards directory records recognition from American Friends of Magen David Adom and American Friends of Rabin Medical Center; it does not disclose underlying payment amounts or establish military-directed funding.^{21, 38}

Counter-Arguments and Evidence Limits

Commercial engagement is not, by itself, political endorsement. Examination of the February 2025 agreement and January 2026 agreement and prospectus identified no independent BofA statement legitimating military operations, supporting territorial claims or endorsing government policy. Identification as bookrunner does not establish authorship of the sovereign issuer’s statements.^{2, 3, 39}

No public evidence identified of formal corporate adoption or sustained republication of Mensah’s remarks as a political campaign. No public evidence identified of verified dismissals for lawful pro-Palestinian expression, targeted exclusion of a Palestinian-rights shareholder proposal, military-directed charitable matching, reservist subsidies or direct corporate donations to named military or settlement organisations.^{7, 8, 21, 14}

The bank’s PAC and political-activities policy establish regulated political activity, without establishing an Israel-specific objective. Medical and emergency-response recognition must not be relabelled as military support. The Resource Centre’s recorded non-response concerns its particular invitation, not every possible corporate communication.^{40, 41, 38, 26}

Named Entities and Evidence Map

Complicity Index Score

Method: V6.5. The following values are final and human-vetted.

• V_MAX: 8.80 Avg_OTHERS: 0.58
• BRS Score: 743 Tier: B (Severe Complicity)

The economic maximum is grounded in recurring, directly documented sovereign underwriting and additional corporate financial relationships; the narrower political record retains the distinction between commercial communication and political endorsement.^{1, 2, 3, 7, 17, 18} The scale-free, evidence-only, vetted method yields the supplied BRS 743/Tier B classification; no separate reviewed numerical rationale was supplied, so this dossier preserves the fixed values without inventing a derivation. The zero military and digital scores remain unchanged while the relevant financial and civilian-technology evidence is disclosed with its limits.

Methodology Note

• This dossier compiles only the four supplied domain audits, with an evidence cut-off of 23 October 2026. External allegations remain attributed, and unresolved findings remain unresolved.
• The supplied scale-free framework distinguishes Impact (I) as activity type, Magnitude (M) as scale and Proximity (P) as directness. The final human-vetted values are preserved exactly.
• Historical activity is marked where material. Divested, reduced or exited exposure receives mitigation rather than being presented as continuing unchanged; the reported Elbit reduction does not establish complete exit.²³
• Entity attribution follows the documented actor and transaction. Group relationships, supplier origins, board affiliations and counterparty conduct do not establish transitive responsibility.
• A verified settlement operation would be assessed in both Economic and Political. No public evidence identified of a qualifying Bank of America settlement operation in these audits.
• “No public evidence identified” records the outcome of the audited checks, not proof that an activity could never exist. Documentary silence, limited non-response and unverified secondary leads are not converted into affirmative allegations.