Bank of America ECONOMIC

Target: Bank of America Corporation, including relevant controlled subsidiaries.

Evidence cut-off: 23 October 2026.

Supply Chain & Sourcing Relationships

Direct supplier relationships

No public evidence identified of Bank of America directly purchasing agricultural commodities from Mehadrin, Hadiklaim, Galilee Export, Agrexco successors, or other identified Israeli produce exporters.

Importer-of-record structure

No public evidence identified of a Bank of America-controlled entity acting as an importer of record for Israeli-origin agricultural or consumer goods.

Seasonal sourcing

No public evidence identified of recurring December–April procurement of Israeli dates, avocados, citrus, herbs, potatoes, or similar agricultural products.

Third-party and indirect sourcing

No public evidence identified of Israeli-origin consumer goods being distributed through Bank of America-owned retail shelves, private-label products, or consumer-goods distributors.

Financial-sector commercial counterparties

A May 3, 2024 amendment to a revolving-credit agreement involving Israeli-incorporated Teva Pharmaceutical Industries Limited and several international subsidiaries identifies Bank of America, N.A. as administrative agent; the relationship concerns corporate credit administration rather than physical product procurement.¹

BofA Securities was identified as an active joint book-running manager for a Teva-related $2.3 billion bond offering that closed on May 28, 2025, with other underwriters including BNP Paribas, HSBC, IMI-Intesa Sanpaolo, and J.P. Morgan.²

Israeli defence procurement and supply relationships

No public evidence identified of a directly documented Bank of America supply contract with the Israel Defense Forces or Israeli Ministry of Defence involving physical goods, equipment, or logistics services.

Product Origin, Labeling & Regulatory Compliance

Settlement-origin products

No public evidence identified of Bank of America marketing agricultural or consumer products originating in Israeli settlements in the occupied West Bank, East Jerusalem, or Golan Heights.

Country-of-origin labeling

No public evidence identified of a Bank of America country-of-origin labeling enforcement action involving Israeli or settlement-produced goods.

Corporate labeling policy

No public evidence identified of a Bank of America corporate product-labeling policy specifically addressing products manufactured or cultivated in occupied Palestinian territory.

Financial-product disclosure

The March 5, 2024 State of Israel underwriting agreement identifies the issuer as the State of Israel and BofA Securities as one of four underwriters; its contractual description concerns sovereign debt rather than a physical product’s geographic origin.³

The February 11, 2025 agreement similarly identifies the State of Israel as issuer and BofA Securities as one of five securities underwriters.⁴

The January 6, 2026 executed agreement again identifies the State of Israel as issuer and BofA Securities as one of five securities underwriters.⁵

Settlement-specific financial products

No public evidence identified of Bank of America issuing a security expressly backed by revenue from a specified Israeli settlement.

Investment, Capital & Financial Exposure

Israeli sovereign debt - March 2024

On March 5, 2024, BofA Securities entered an underwriting agreement for an $8 billion State of Israel sovereign bond offering, comprising $2 billion due 2029, $3 billion due 2034, and $3 billion due 2054.³

Schedule I assigned BofA Securities $500 million of the 2029 bonds, $750 million of the 2034 bonds, and $750 million of the 2054 bonds, producing a total contractual allocation of $2 billion.³

The same agreement identifies BNP Paribas, Deutsche Bank and Goldman Sachs as the other three underwriters, each with a $2 billion allocation.³

BofA Securities managing director Sandeep Chawla signed the agreement on behalf of the bank.³

Israeli sovereign debt - February 2025

On February 11, 2025, BofA Securities entered a further State of Israel underwriting agreement covering $5 billion in sovereign debt, divided equally between bonds due 2030 and 2035.⁴

Schedule I assigned BofA Securities $500 million in each maturity, totaling $1 billion, alongside Citigroup, Deutsche Bank, Goldman Sachs and J.P. Morgan.⁴

The agreement was signed for BofA Securities by managing director Jon Klein.⁴

Arnold & Porter confirmed that the offering was completed on February 19, 2025, identifying Bank of America Merrill Lynch among the joint book-running managers.⁶

Israeli sovereign debt - January 2026

On January 6, 2026, BofA Securities entered a third identified underwriting agreement for a $6 billion State of Israel offering, with $2.25 billion due 2031, $2 billion due 2036, and $1.75 billion due 2056.⁵

Schedule I assigned BofA Securities $450 million, $400 million and $350 million respectively, totaling $1.2 billion.⁵

The other underwriters were Citigroup, Deutsche Bank, Goldman Sachs and J.P. Morgan, each receiving an equivalent allocation.⁵

Sandeep Chawla signed the agreement on behalf of BofA Securities.⁵

Arnold & Porter confirmed that the transaction completed on January 13, 2026, with Bank of America acting as one of the joint book-running managers.⁷

Documented financing amounts

The three executed agreements establish BofA Securities underwriting allocations totaling $4.2 billion across the March 2024, February 2025 and January 2026 sovereign issuances, representing contractual primary-market allocations rather than verified retained investments or net credit exposure.^{3, 4, 5}

Independent financial-sector investigation

On February 14, 2025, BankTrack published research conducted with PAX and Profundo identifying Bank of America among seven banks underwriting Israeli sovereign debt during the period from October 7, 2023 to January 2025.⁸

BankTrack reported $19.4 billion in total Israeli sovereign issuance during that research period and identified Goldman Sachs, Bank of America, Deutsche Bank, BNP Paribas, Citi, Barclays and JPMorgan Chase as the relevant underwriting institutions.⁸

BankTrack characterised the issuance as financing associated with Israel’s war expenditure; the executed underwriting agreements separately establish the State of Israel as borrower without allocating specific bond proceeds to individual government departments or military programmes.^{8, 3, 4}

Constructive-notice chronology

The March 2024 underwriting transaction predates July 19, 2024, while the February 2025 and January 2026 transactions occurred after both July 19, 2024 and November 2024.^{3, 4, 5}

Israeli corporate lending and capital markets

The May 2024 Teva credit-agreement amendment identifies Bank of America, N.A. as administrative agent for a financing arrangement involving Teva Pharmaceutical Industries Limited and foreign subsidiaries.¹

BofA Securities subsequently participated as an active joint book-running manager in Teva’s May 2025 bond issuance, showing a separate continuing capital-markets relationship with the pharmaceutical group.²

Prospective acquisition financing involving ZIM

On February 16, 2026, Hapag-Lloyd disclosed an agreement to acquire all outstanding shares of Israeli shipping company ZIM for approximately $4.2 billion, with external financing of up to $2.5 billion and completion subject to regulatory and governmental approvals.⁹

Hapag-Lloyd’s disclosure states that the transaction would involve a merger through an Israeli subsidiary and arrangements with FIMI Opportunity Funds relating to the Israeli state’s special rights in ZIM.⁹

A separate communication reproduced by CSAV identifies FIMI as the prospective controller of an entity that would receive twelve vessels and the assets needed to operate three shipping routes as part of the proposed restructuring.¹⁰

No public evidence identified in the cited issuer disclosures establishing that Bank of America acquired ZIM or obtained controlling equity ownership of ZIM.

Acquired Israeli operating companies

Bank of America completed its acquisition of Merrill Lynch & Co. on January 1, 2009 [pre-2020], following Federal Reserve approval announced in November 2008.^{11, 12}

Bank of America’s subsidiary disclosures for financial years 2023 and 2024 identify Merrill Lynch Israel Ltd. as an Israeli-incorporated subsidiary located in Tel Aviv, showing that the Israeli operating entity remained within the Bank of America corporate reporting perimeter during those years.^{13, 14}

The company’s currently published office directory also identifies a Tel Aviv business location, providing additional evidence of continuing Israeli operational presence.¹⁵

The disclosed subsidiary lists do not establish a stand-alone acquisition price, exact percentage of equity ownership, Israeli subsidiary revenue, or factory/manufacturing operations for Merrill Lynch Israel Ltd.^{13, 14}

No public evidence identified of Bank of America acquiring controlling operating ownership of Teva, ZIM, an Israeli agricultural producer, or an Israeli defence manufacturer.

Foreign direct investment

The documented Merrill Lynch acquisition incorporated an existing Israeli financial-services entity into the Bank of America group, and subsequent SEC exhibits continue to identify Merrill Lynch Israel Ltd. as an Israeli subsidiary.^{11, 12, 13, 14}

No public evidence identified of a Bank of America-owned Israeli manufacturing plant, agricultural estate, commercial logistics warehouse, or data centre.

Research, development and technology

No public evidence identified of a Bank of America-controlled Israeli R&D laboratory, software-development centre, or Israeli government Preferred Technology Enterprise designation.

Portfolio and fund exposure

An Israeli venture-capital directory identifies historical investment and underwriting activity attributed to Merrill Lynch Israel, including historical portfolio entries and Israeli technology-sector transactions; its records do not establish the bank’s current holdings or beneficial ownership of those companies.¹⁶

No public evidence identified establishing a verified current total for Bank of America’s proprietary Israeli sovereign-bond holdings, Israeli defence-equity holdings, or settlement-company equity exposure.

Insurance underwriting

No public evidence identified of a specific Bank of America insurance-underwriting contract covering Israeli military operations or a named settlement project.

Settlement-specific loans

No public evidence identified of a direct lending agreement between Bank of America and a specifically identified settlement municipality, settlement real-estate developer, or OHCHR-listed settlement enterprise.

On December 5, 2024, BofA Securities, Inc. entered into an underwriting agreement with Israeli-incorporated cybersecurity company CyberArk Software Ltd. and Triton Seller, LP, an affiliate of funds managed by Thoma Bravo, L.P., for a secondary public offering of 1,142,538 CyberArk ordinary shares. Schedule I identifies BofA Securities as the sole underwriter, contractually purchasing all 1,142,538 shares at $324.46 per share. CyberArk’s contemporaneous announcement explicitly identifies BofA Securities as the sole book-running manager. CyberArk’s Form 6-K confirms that the transaction closed on December 9, 2024. This establishes a direct equity-capital-markets relationship between BofA Securities, the Israeli-incorporated issuer and its selling shareholder.^{17, 18, 19}

The transaction was a secondary sale of existing CyberArk shares held by Triton Seller, LP, rather than a primary issuance raising new equity capital for CyberArk. At the contractual purchase price of $324.46 per share, the 1,142,538 shares represented $370,707,879.48 in gross proceeds to the selling shareholder before expenses. CyberArk expressly confirmed that it received no proceeds from the offering. Accordingly, the approximately $370.7 million represents consideration for a shareholder’s equity disposal, not new financing received by CyberArk. The agreement establishes BofA Securities’ underwriting and distribution role but does not establish that it acquired a permanent equity stake in CyberArk or quantify its realised underwriting profit.^{17, 18, 19}

Operational Presence & Market Activity

Israeli physical footprint

Bank of America’s current international office directory lists an office at 1 Azrieli Center, Round Tower, 35th Floor, Tel Aviv 67021, Israel.¹⁵

Bank of America’s 2023 subsidiary exhibit identifies Merrill Lynch Israel Ltd. as an entity incorporated in Israel and located in Tel Aviv.¹³

Its 2024 subsidiary exhibit repeats the identification of Merrill Lynch Israel Ltd., establishing continuity across two annual reporting periods.¹⁴

Historical Israeli management and market activity

The Israeli financial-sector database IVC identifies Merrill Lynch Israel as a Tel Aviv operation and names Yoram Inbar as Israel country executive and Gilad Rosolio as a director of Israel investment banking in its historical directory records.¹⁶

The same directory records historical capital-market transactions involving Israeli companies including Teva, Amdocs, AudioCodes and other technology-sector issuers, although individual transaction entries predate 2020 and must be treated as [pre-2020] unless separately updated.¹⁶

The IVC record identifies the business with investment-banking and securities activity, rather than an Israeli consumer retail-bank network.¹⁶

Financial-sector positioning

BofA Securities’ participation in State of Israel sovereign bond syndicates in 2024, 2025 and 2026 documents recurring international debt-capital-market activity involving Israel.^{3, 4, 5}

Its separate 2025 Teva underwriting role documents capital-market activity involving an Israeli-incorporated corporate issuer.²

Employment

Bank of America’s corporate governance materials describe a group workforce exceeding 210,000 employees, but this company-wide measure cannot be used as an Israeli employee count.²⁰

No public evidence identified establishing the current number of Bank of America employees physically working in Israel.

Israeli tax and regulatory status

Merrill Lynch Israel Ltd. is identified as an Israel-incorporated subsidiary in the bank’s SEC exhibits; the exhibits do not quantify Israeli corporate income tax or specify a local tax incentive classification.^{13, 14}

No public evidence identified of Bank of America or Merrill Lynch Israel holding Preferred Technology Enterprise status.

Settlement operations

No public evidence identified of a Bank of America-owned or controlled branch, office, warehouse, retail location or settlement-specific physical facility within the occupied West Bank, East Jerusalem or Golan Heights.

Military employment and charitable programmes

No public evidence identified of a specifically documented Israeli reservist salary-support programme operated by Bank of America.

No public evidence identified establishing an exact Bank of America employer-matching payment to a named Israeli military-support or settlement organisation.

Corporate Structure & Foundational Ties

Founding and domicile

Bank of America Corporation’s federal regulatory acquisition records identify it as a Charlotte, North Carolina banking organisation, and the Federal Reserve’s November 2008 approval concerned its acquisition of New York-based Merrill Lynch & Co.¹¹

Bank of America’s public affiliate directory identifies Bank of America Corporation, Bank of America, N.A., BofA Securities and multiple Merrill entities within the same corporate family.²¹

No public evidence identified that Bank of America Corporation was originally founded or incorporated in Israel.

Israeli-Nexus Floor - founding and headquarters

The current international office directory identifies Tel Aviv as an overseas location within a broader global network of Bank of America offices; Israel is not identified there as the corporation’s headquarters.¹⁵

No public evidence identified that Bank of America Corporation’s principal headquarters or principal place of management is in Israel.

Israeli-Nexus Floor - tax residency

The group’s disclosures identify Merrill Lynch Israel Ltd. as incorporated in Israel, but do not establish Israeli tax residency for the US parent company.^{13, 14}

No public evidence identified of Israeli Preferred Technology Enterprise status for Bank of America Corporation or its identified Israeli subsidiary.

Israeli-Nexus Floor - beneficial ownership

The bank’s affiliate disclosures identify BofA Securities and Merrill entities as members of the Bank of America corporate family.²¹

No public evidence identified establishing Israeli majority or controlling beneficial ownership of Bank of America Corporation.

Acquisition history

On November 26, 2008 [pre-2020], the Federal Reserve approved Bank of America Corporation’s acquisition of Merrill Lynch & Co., identifying the merger as a transaction involving two US financial institutions.¹¹

Bank of America’s January 1, 2009 announcement [pre-2020] confirmed completion of the purchase and described the expansion of its wealth-management and international investment-banking operations.¹²

Merrill Lynch Israel Ltd. remained identified within the group’s subsidiary reporting in 2023 and 2024, establishing the continuing presence of an Israeli-incorporated subsidiary after that historical acquisition.^{13, 14}

Corporate governance

Bank of America’s current management disclosures identify Brian T. Moynihan as Chair of the Board and Chief Executive Officer, with board service dating from January 2010.²⁰

Its 2026 annual shareholder materials identify a twelve-member slate of board nominees and describe Moynihan as Chair and CEO.²²

A February 2026 regulatory filing disclosed that the board approved total 2025 compensation of $41 million for Moynihan, compared with $35 million for 2024; the filing provides information on executive governance rather than evidence of Israeli personal investments.²³

Controlling-principal investments

No public evidence identified establishing that Brian Moynihan or another specifically identified Bank of America controlling principal personally controls an Israeli defence, settlement, industrial, or infrastructure company through a family office or private investment vehicle.

State and institutional relationships

BofA Securities entered directly into executed underwriting agreements with the government of Israel in March 2024, February 2025 and January 2026, creating documented contractual relationships with the Israeli sovereign issuer.^{3, 4, 5}

The executed January 2026 agreement identifies Israeli Ministry of Finance officials as state signatories and BofA Securities managing director Sandeep Chawla as the bank’s signatory.⁵

Structural governance ties

No public evidence identified of an Israeli-government golden share, statutory voting veto, government-appointed board seat, or charter restriction controlling Bank of America Corporation’s strategy.

The February 2026 Hapag-Lloyd disclosure identifies Israeli state special rights in ZIM, but those rights concern ZIM’s proposed corporate transaction rather than Bank of America’s ownership or governance.⁹

Profit Repatriation & Economic Contribution

State financing flows

The March 2024 State of Israel bond issuance assigned BofA Securities a $2 billion primary-underwriting allocation within an $8 billion transaction.³

The February 2025 issuance assigned it a $1 billion allocation within a $5 billion transaction.⁴

The January 2026 issuance assigned it a $1.2 billion allocation within a $6 billion transaction.⁵

These contracts establish participation in the financing and distribution of Israeli sovereign obligations, but they do not quantify underwriting fees, final investor positions, or the amount of the securities retained on Bank of America’s balance sheet.^{3, 4, 5}

Corporate financing flows

Bank of America, N.A.’s May 2024 administrative-agent role under Teva’s revolving-credit agreement establishes a direct commercial banking function involving an Israeli-incorporated parent and international borrowing entities.¹

BofA Securities’ participation in Teva’s approximately $2.3 billion May 2025 bond offering establishes a separate capital-markets relationship involving an Israeli corporate group.²

The disclosed transaction material does not identify a precise amount of interest income, agency fees, underwriting profit or taxable Israeli revenue attributable to Bank of America.^{1, 2}

Israeli revenue attribution

No public evidence identified establishing Bank of America’s annual Israeli-market revenue as a separately reported geographic amount.

Israeli tax contribution

No public evidence identified establishing an annual corporate-income-tax amount paid in Israel by Merrill Lynch Israel Ltd. or other Bank of America entities.

Profit repatriation

The subsidiary disclosures establish an Israeli-incorporated group entity, but do not provide a separate dividend or intercompany-payment schedule demonstrating the amount of profit repatriated from Israel to Bank of America’s US parent.^{13, 14}

No public evidence identified establishing a material reverse dividend flow from the US parent into an Israeli controlling shareholder.

Employment contribution

Bank of America publicly lists a Tel Aviv office and identifies Merrill Lynch Israel Ltd. within its subsidiary structure; these disclosures establish a local commercial presence without quantifying associated Israeli salaries, payroll taxes or employment expenditure.^{15, 13, 14}

Economic ecosystem role

The IVC directory records historical Merrill Lynch Israel transactions involving Israeli technology and pharmaceutical companies and identifies an investment-banking business linked to the country’s capital markets.¹⁶

Bank of America’s 2024–2026 sovereign-debt underwriting activity documents a continuing role in international capital-market transactions for the State of Israel.^{3, 4, 5}

Its 2025 Teva bond-underwriting participation documents an additional corporate financing role outside sovereign debt.²

Occupied-territory revenue

No public evidence identified establishing revenue generated by Bank of America from a specifically identified commercial establishment, property, financial contract or retail transaction located within an Israeli settlement.

Government or military expenditure earmarking

The executed sovereign underwriting contracts identify the State of Israel as issuer; the cited contractual schedules do not allocate particular bond proceeds to a named military unit, weapons programme or settlement construction project.^{3, 4, 5}