INDEX / DIRECTORY / BANK OF AMERICA / DIGITAL

Bank of America DIGITAL

DIGITAL INFRASTRUCTURE AUDIT UPDATED 2026-10-23
Digital Score 0.00 /10 B Bank of America - Complicity Index 743
Digital 0.00

Evidence-only forensic audit. Scoring happens downstream - see the main dossier for the composite assessment.

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Target: Bank of America Corporation, including relevant subsidiaries Research date: 23 October 2026 Evidence period: Historical records through October 2026 Domain: Digital technology, cybersecurity, surveillance, cloud infrastructure, artificial intelligence and technology-sector relationships

Enterprise Technology Stack & Vendor Relationships

CyberArk - privileged access management

A Bank of America recruitment advertisement published in 2026 identifies CyberArk and HashiCorp Vault as technologies subject to enterprise adoption within the bank’s Privileged Access Management programme. The position involves application onboarding, operational governance, secrets management and alignment with enterprise security requirements. This is direct evidence of Bank of America’s use or adoption of CyberArk technology within an enterprise security function; procurement value, license count and hosting geography are undisclosed.1

NICE - voice recording infrastructure

A 2026 Bank of America recruitment advertisement for a Singapore-based voice recording engineering position requires practical experience with NICE voice recording systems. The stated responsibilities include engineering support, migrations, upgrades and maintenance of voice recording and trading-floor communications applications, including associated IPC, Cisco and Avaya technologies. This supports a current operational relationship with NICE technology.2

A third-party enterprise technology database reports that Bank of America UK implemented NICE Call Center Recording System technology in 2018, including integration with Avaya and enterprise communications systems at Chester and Bromley locations. This historical deployment is reported by a secondary supplier database rather than a Bank of America procurement record; its precise implementation details are not independently confirmed by the 2026 recruitment advertisement. [pre-2020] Historical deployment; contemporary operational requirements are separately documented.3

Verint / OpinionLab - digital feedback and customer analytics

Verint published a Bank of America customer account on 31 October 2017 describing a partnership with OpinionLab for website and branch customer-feedback analysis. The publication describes real-time customer feedback, text analysis, categorisation of support requests and automated response workflows. It reports reductions in support demand and customer attrition associated with these applications. [pre-2020] The relationship is historically documented; continuation under the same product or contractual arrangements in 2026 is unconfirmed.4

Verint EdgeVMS Vid-Center - historical video surveillance lead

An enterprise software database identifies Bank of America as a reported 2018 customer of Verint EdgeVMS Vid-Center, describing branch and ATM video review used in fraud investigations and transaction-dispute adjudication. The record is secondary evidence; no corresponding original Bank of America purchasing contract was established. [pre-2020] Historical deployment reported, current deployment status unknown.5

Scale of technological dependency

The named CyberArk and NICE applications address privileged enterprise access and communications recording, respectively. Their operational functions are supported by the bank’s own 2026 recruitment descriptions, but the sources do not establish what percentage of Bank of America’s total infrastructure depends on either supplier.1, 2

Enterprise procurement and third-party oversight

Bank of America’s documented technology activities include internal cybersecurity operations, platform engineering, AI development and management of external technology risks. Its corporate disclosures identify substantial expenditure on digital services and technology initiatives, but do not publicly enumerate all enterprise software suppliers or their individual contract values.6, 7

The July 2026 announcement concerning MDSec Consulting Limited establishes a proposed acquisition of a British cybersecurity consultancy with approximately 65 specialists. The transaction was expected to close in the fourth quarter of 2026, subject to regulatory approvals. Completion was not independently verified in this research.8

Other Israeli-origin software vendors

No public evidence identified establishing direct Bank of America licensing or operational deployment of Wiz, Check Point, SentinelOne, Claroty, Palo Alto Networks or comparable additional Israeli-origin cybersecurity suppliers within the reviewed primary records.

Integrator deployment of Israeli-origin technology

No public evidence identified establishing that a named external systems integrator deployed additional Israeli-origin technology under a Bank of America contract.

Surveillance, Biometrics & Retail Technology

Customer analytics

Verint’s historical OpinionLab publication documents digital feedback gathering, customer-response analysis and support escalation. These functions involved behavioural and customer-experience analytics, rather than a documented military or law-enforcement surveillance application. [pre-2020] The publication dates from 2017; continued deployment is unconfirmed.4

Branch and ATM monitoring

A third-party customer database reports Bank of America’s historical use of Verint EdgeVMS Vid-Center for reviewing video from banking locations and ATMs during fraud investigations. The recorded purpose was transaction verification and investigation of disputed activity. [pre-2020] The reported implementation dates from 2018 and requires additional procurement-level confirmation.5

Facial recognition and biometrics

No public evidence identified establishing that Bank of America uses Israeli-origin facial recognition, gait identification or biometric surveillance products supplied by Oosto/AnyVision, BriefCam, Trigo, Trax or comparable firms.

Predictive monitoring and workforce surveillance

No public evidence identified establishing deployment by Bank of America of Israeli-origin predictive policing, social-media surveillance or workforce monitoring systems.

Third-party or bundled surveillance technology

No public evidence identified establishing indirect provision of Israeli-origin biometric surveillance technology through Bank of America’s managed security providers or other enterprise technology suppliers.

SentinelOne relationship assessment

A SentinelOne publication discussing historical banking insider threats includes Bank of America as an example of an institution affected by insider misconduct. The article discusses the banking threat environment but does not identify Bank of America as a purchaser or operator of SentinelOne technology. It therefore does not establish a procurement relationship.9

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

Israeli corporate presence

Bank of America’s official international locations directory identifies a Tel Aviv office at 1 Azrieli Center, Round Tower, 35th floor, Tel Aviv. The office is listed as part of the bank’s international business network in information accessible in October 2026.10

The bank’s employee and contractor privacy-notice directory separately includes Israel among the jurisdictions for which local data-protection documentation is provided. This establishes an Israel-specific employment and data-governance framework.11

Data processing and jurisdiction

Bank of America’s CashPro Digital Privacy Notice, dated 12 April 2023, states that personal information may be stored or processed in countries where the bank maintains facilities or engages service providers. It also acknowledges that government authorities in those jurisdictions may be legally entitled to access information under applicable laws. The notice does not identify particular Israeli data centres, processing subcontractors or categories of customer data transferred to Israel.12

A separate Bank of America privacy notice covering media and investor contacts similarly describes international data processing, cross-border transfers and possible lawful access by foreign authorities. These disclosures establish that cross-border processing is part of the bank’s data-protection framework, but do not demonstrate that any particular customer dataset is processed in Israel.13

Digital financial data processed by Bank of America

Bank of America’s public operating statistics identify CashPro as a major corporate digital banking platform. The company reports that more than 35,000 corporate and commercial clients use CashPro and that clients approved approximately $1.2 trillion in payments through the CashPro application during 2025. These activities involve substantial financial-data processing, although the public figures do not identify the countries in which individual transactions or records are processed.6

The same corporate information describes extensive domestic and international electronic payment operations, including wire transfers and commercial transactions. These disclosures establish the scale of Bank of America’s digital financial infrastructure, without identifying Israel-specific routing or storage infrastructure.6

Israeli data centres

No public evidence identified establishing that Bank of America owns, leases or operates a data centre in Israel.

Project Nimbus and Israeli government cloud procurement

No public evidence identified establishing Bank of America as a Project Nimbus contractor, subcontractor, cloud operator or provider of technical infrastructure under that programme.

Sovereign cloud and state data-residency services

No public evidence identified establishing Bank of America provision of sovereign cloud, government data-hosting or infrastructure-resilience services to Israeli military, intelligence or other state bodies.

Israeli settlement data infrastructure

No public evidence identified establishing that Bank of America operates a dedicated digital banking platform, data-processing facility or technology-services contract within an Israeli settlement in occupied territory.

Defence, Intelligence & Security Sector Technology Relationships

Israeli military and intelligence procurement

No public evidence identified establishing a Bank of America technology procurement, licensing, managed-service or digital infrastructure contract with the Israel Defense Forces, Israeli Ministry of Defence or Israeli intelligence agencies.

Israeli military technology provision through subsidiaries

No public evidence identified establishing that a Bank of America subsidiary supplies enterprise cybersecurity software, surveillance platforms, AI systems or cloud infrastructure directly to Israeli military or intelligence agencies.

Dual-use technologies

Bank of America’s verified technology activities include cybersecurity operations, banking communications recording, AI-enabled customer service and financial-data processing. The reviewed corporate records describe applications within banking and enterprise operations; they do not establish deployment of these systems by Israeli security organisations.1, 2, 7

Offensive cyber capabilities

Bank of America announced on 30 July 2026 that it intended to acquire MDSec Consulting Limited, describing the business as a specialist cybersecurity consultancy. The announcement identifies the firm’s headquarters in Macclesfield, England, and discusses technical information-security expertise. It does not establish development or sale of digital weapons to Israel.8

No public evidence identified establishing Bank of America development, sale, licensing or maintenance of offensive cyber weapons, zero-day exploit products or state-directed digital attack systems for Israeli government agencies.

Purpose-built targeting systems - Military boundary

No public evidence identified establishing that Bank of America develops or supplies software designed primarily for kinetic targeting, fire-control decisions or weapons effects for Israeli military use.

AI, Algorithmic & Autonomous Systems

Bank of America’s commercial AI activities

Bank of America’s April 2025 announcement identifies AI applications supporting internal research, customer service, employee productivity and analysis of customer communications. These include internally developed research tools and generative AI capabilities intended to summarise call recordings and improve contact-centre workflows.7

In March 2026, Chair and Chief Executive Officer Brian Moynihan reported continued adoption of Erica, Bank of America’s AI-based virtual assistant, and described internal AI applications supporting employees and operations across multiple banking functions. He reported that approximately 20 million customers used Erica during the fourth quarter of 2025, generating nearly 200 million interactions.14

AI-driven financial information processing

The bank’s April 2025 disclosure describes an internally developed generative AI research platform that allows Global Markets personnel to search, summarise and synthesise research and market commentary. The same disclosure identifies AI-assisted summarisation of client call recordings, demonstrating commercial use of language-processing technology on banking information.7

AI technology development and patents

A March 2024 Bank of America announcement reported approximately 6,600 granted patents and pending patent applications, with AI, information security, payments and digital banking among the technology categories. Its portfolio included 644 patents granted during 2023.15

An October 2024 corporate announcement reported approximately 1,100 patents and pending applications relating to AI and machine learning, representing growth since 2022. The published technology portfolio concerned financial services and associated enterprise applications.16

AI provision to Israeli state institutions

No public evidence identified establishing direct Bank of America supply of AI or machine-learning platforms to Israeli government, military or intelligence agencies.

Civilian surveillance datasets and training data

No public evidence identified establishing that Bank of America’s AI systems were trained on Palestinian civilian surveillance datasets, intercepted communications or biometric information originating from occupied territories.

Autonomous tracking and targeting

No public evidence identified establishing Bank of America provision of autonomous threat-tracking, target-identification or weapons-control AI to Israeli military or security organisations.

Technology Ecosystem & R&D Footprint

Technology investment and internal research

Bank of America reported approximately $13 billion in annual technology expenditure in 2025, including approximately $4 billion allocated to new technology initiatives. The disclosure identifies AI, information security, analytics and digital banking among the bank’s technology investment areas.7

Bank of America’s updated corporate operating information describes a substantial international invention programme, approximately 8,900 granted patents and pending applications, and more than 1,800 AI-focused patents and applications. The reported figures cover the bank’s international operations and do not independently identify an Israeli R&D location.6

Israeli engineering offices

Bank of America’s official location directory confirms a Tel Aviv business office, but the location entry does not identify it as a software engineering facility, AI laboratory, cybersecurity research centre or development campus.10

No public evidence identified establishing a dedicated Bank of America technology R&D centre or accelerator programme operating within Israel.

Technology acquisitions

Bank of America’s July 2026 agreement to acquire MDSec Consulting Limited concerns a British information-security consultancy. The corporate announcement provides the proposed acquisition’s cybersecurity rationale, staffing and expected completion period; it does not identify an Israeli ownership or technology-development connection.8

No public evidence identified establishing a completed Bank of America acquisition of an Israeli-domiciled cybersecurity, surveillance, AI or defence-technology developer during the period reviewed.

Institutional securities holdings

Bank of America Corporation filed Form 13F-HR on 14 August 2026 for the quarter ended 30 June 2026. The SEC filing identifies the corporation as an institutional investment manager and provides an information table of reportable securities holdings.17, 18

The existence of an institutional investment portfolio does not itself establish a strategic acquisition, controlling interest, enterprise software procurement or operational technology partnership. Individual positions in Israeli-origin technology firms were not independently reconciled against the complete filing information table in this review.17, 18

Controlling principals and corporate governance

Bank of America’s corporate governance disclosures identify Brian Moynihan as Chair and Chief Executive Officer and Lionel Nowell III as Lead Independent Director. The official director directory also describes the backgrounds, external appointments and professional qualifications of board members.19

On 21 October 2026, Bank of America announced the appointments of Jim Fitterling and Bill Thomas to its board. The announcement identifies Fitterling’s leadership at Dow and Thomas’s previous leadership of KPMG International, including experience with technology transformation and AI investment programmes.20

No public evidence identified establishing a qualifying personal investment, controlling equity interest or board role by a named Bank of America controlling principal in an Israeli offensive-cyber, intelligence-surveillance or military-technology company.

Academic partnerships and intellectual property

Bank of America’s public patent disclosures establish substantial internally generated technology and intellectual property involving inventors in multiple countries. The reviewed publications do not identify a specific patent assignment, joint-development agreement or technology-licensing arrangement with Technion, Hebrew University, Weizmann Institute or another Israeli-domiciled research institution.15, 16

No public evidence identified establishing an Israel-specific co-development or patent-licensing agreement.

Civil Society Scrutiny & Regulatory History

United Nations settlement-business investigations

The Business & Human Rights Resource Centre reported on the September 2026 update of the UN OHCHR database concerning business enterprises involved in activities connected with Israeli settlements in occupied Palestinian territory. The update concerns allegations assessed by the UN Human Rights Office and distinguishes specific categories of business activity.21

The 2026 database reporting provides context for investigations into settlement-related corporate conduct. The reviewed material does not independently establish a Bank of America digital infrastructure, surveillance software or technology-services contract benefiting an identified settlement.21

Technology-specific civil-society findings

No public evidence identified from the reviewed Who Profits, AFSC Investigate, Amnesty International, Human Rights Watch, B’Tselem, Al-Haq or related search results establishing a specific Bank of America technology provision to Israeli military, intelligence or settlement authorities.

Boycott and divestment scrutiny

No public evidence identified establishing an organised campaign specifically directed at Bank of America’s provision of Israeli military software, surveillance technology or government cloud infrastructure.

Technology-related regulatory proceedings

No public evidence identified establishing a regulatory enforcement action, export-control proceeding or sanctions investigation concerning Bank of America’s provision of digital surveillance, cloud or cybersecurity technology to Israeli government or military entities.

Corporate cybersecurity oversight

Bank of America’s corporate governance materials describe board-level oversight of cybersecurity, information security and technology risk. Its annual shareholder materials identify cybersecurity and technology experience among the board’s collective competencies and describe established committee oversight arrangements.19, 21, 11

Publicly documented customer-data practices

Bank of America’s CashPro privacy notice acknowledges international storage and processing of personal information, subject to applicable data-protection requirements and lawful government-access provisions. The disclosure does not identify an Israel-specific cross-border data transfer, government-access request or regulatory investigation.12

Post-July and post-November 2024 continuation

The 2026 Bank of America recruitment advertisements establish continued enterprise technology work involving CyberArk and NICE after 19 July 2024 and November 2024. Neither recruitment advertisement identifies an Israeli state, military or settlement customer for those technologies.1, 2

No public evidence identified establishing post-July 2024 or post-November 2024 continuation of a specifically documented Bank of America technology-services contract with Israeli military, intelligence or settlement authorities.

Footnotes

  1. Bank of America Careers, 2026, “Privileged Access Management (PAM) Senior Specialist - HashiCorp Vault experience required.” https://careers.bankofamerica.com/en-us/job-detail/26027229/privileged-access-management-pam-senior-specialist-hashicorp-vault-experience-required-multiple-locations ↩ ↩2 ↩3 ↩4

  2. Bank of America Careers, 2026, “Vice President, Voice Recording Engineer, Employee Experience Technology.” https://careers.bankofamerica.com/en-us/job-detail/26030849/vice-president-voice-recording-engineer-employee-experience-technology-singapore-singapore?gh_src=Leadership+Triangle+job+board ↩ ↩2 ↩3 ↩4

  3. Apps Run The World, “List of NICE Call Center Recording System Customers,” historical Bank of America UK deployment listing, accessed October 2026. https://www.appsruntheworld.com/customers-database/products/view/nice-call-center-recording-system ↩

  4. Verint, 31 October 2017, “Digital feedback is a powerful builder of brand trust at Bank Of America.” https://www.verint.com/blog/digital-feedback-is-a-powerful-builder-of-brand-trust-at-bank-of-america/ ↩ ↩2

  5. Apps Run The World, “List of Verint EdgeVMS Vid-Center Customers,” historical Bank of America deployment listing, accessed October 2026. https://www.appsruntheworld.com/customers-database/products/view/verint-edgevms-vid-center ↩ ↩2

  6. Bank of America, “Bank of America Fast Facts,” accessed October 2026. https://newsroom.bankofamerica.com/content/newsroom/company-overview/bank-of-america-fast-facts.html ↩ ↩2 ↩3 ↩4

  7. Bank of America, April 2025, “AI Adoption by BofA’s Global Workforce Improves Productivity, Client Service.” https://newsroom.bankofamerica.com/content/newsroom/press-releases/2025/04/ai-adoption-by-bofa-s-global-workforce-improves-productivity - cl.html ↩ ↩2 ↩3 ↩4 ↩5

  8. Bank of America, 30 July 2026, “Bank of America to Acquire Information Security Consultancy MDSec Consulting Limited.” https://newsroom.bankofamerica.com/content/newsroom/press-releases/2026/07/bank-of-america-to-acquire-information-security-consultancy-mdse.html ↩ ↩2 ↩3

  9. SentinelOne, “Financial Cyber Threats: 10 Cases of Insider Bank Attacks,” published 2023. https://www.sentinelone.com/blog/financial-cyber-threats-10-cases-of-insider-bank-attacks/ ↩

  10. Bank of America, official international office directory, accessed October 2026. https://business.bofa.com/content/boaml/en_us/locations.html?tabcomponent=main-tab&tabid=europeMiddleEastAndAfrica ↩ ↩2

  11. Bank of America Careers, “Employee and Contractor Data Protection Notices,” accessed October 2026. https://careers.bankofamerica.com/en-us/employee-and-contractor-data-protection-notices ↩ ↩2

  12. Bank of America, CashPro Digital Privacy Notice, updated 12 April 2023. https://developer-ex-prod.bankofamerica.com/PHXcms/public/content/cashproonline/html/CashProOnline/OnlinePrivacyPolicy/OnlinePrivacyPolicy_v1.html ↩ ↩2

  13. Bank of America, Data Privacy Notice for Media and Investor Contacts, accessed October 2026. https://newsroom.bankofamerica.com/content/newsroom/home/data-privacy-notice-for-media-and-investor-contacts.html ↩

  14. Bank of America, March 2026, “A letter to shareholders from Chair and CEO Brian Moynihan.” https://newsroom.bankofamerica.com/content/newsroom/stories/2026/03/a-letter-to-shareholders-from-chair-and-ceo - brian-moynihan.html ↩

  15. Bank of America, 6 March 2024, “BofA Patents Increase Nearly 70% in 5 Years.” https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/03/bofa-patents-increase-nearly-70 - in-5-years.html ↩ ↩2

  16. Bank of America, 23 October 2024, “AI Patents at BofA Increase 94% Since 2022.” https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/10/ai-patents-at-bofa-increase-94 - since-2022.html ↩ ↩2

  17. U.S. Securities and Exchange Commission, Bank of America Corporation, Form 13F-HR, quarter ended 30 June 2026. https://www.sec.gov/Archives/edgar/data/70858/000007085826000442/xslForm13F_X02/primary_doc.xml ↩ ↩2

  18. U.S. Securities and Exchange Commission, filing detail for Bank of America Corporation Form 13F-HR, filed 14 August 2026. https://www.sec.gov/Archives/edgar/data/70858/000007085826000442/0000070858-26-000442-index.htm ↩ ↩2

  19. Bank of America Investor Relations, “Management Team & Directors,” accessed October 2026. https://investor.bankofamerica.com/corporate-governance/management-team-and-directors ↩ ↩2

  20. Bank of America, 21 October 2026, “Bank of America Names Jim Fitterling and Bill Thomas to Board of Directors.” https://newsroom.bankofamerica.com/content/newsroom/press-releases/2026/10/bank-of-america-names-jim-fitterling-and-bill-thomas-to-board-of.html ↩

  21. Business & Human Rights Resource Centre, September 2026, “I/OPT: UN updates database of companies allegedly involved in illegal Israeli settlements, listing 214 companies from 11 countries.” https://www.business-humanrights.org/en/latest-news/iopt-un-updates-database-of-companies-involved-in-illegal-israeli-settlements-listing-214-companies-from-11-countries/ ↩ ↩2 ↩3