Target: Bank of America Corporation Research date: 23 October 2026 Scope: Israeli military, defence-industry and military-adjacent activities, including finance, supply chains, controlling principals and occupied territories.
Direct Defence Contracting & Procurement
Israeli sovereign financing - March 2024
On 5 March 2024, BofA Securities, Inc., a Bank of America group entity, entered into an underwriting agreement with the State of Israel alongside BNP Paribas, Deutsche Bank and Goldman Sachs for an $8 billion sovereign bond offering, comprising $2 billion due in 2029, $3 billion due in 2034 and $3 billion due in 2054.1
The SEC prospectus assigns BofA Securities $500 million of the 2029 notes, $750 million of the 2034 notes and $750 million of the 2054 notes, representing $2 billion in aggregate underwriting commitments.2
Cravath, Swaine & Moore confirmed that the transaction closed on 12 March 2024, while the SEC prospectus identified BofA Securities as a joint book-running manager.3, 2
Israeli sovereign financing - February 2025
On 11 February 2025, the State of Israel entered into a further underwriting agreement with BofA Securities, Citigroup Global Markets, Deutsche Bank, Goldman Sachs and J.P. Morgan Securities for $5 billion in sovereign bonds, divided equally between 2030 and 2035 maturities.4
Schedule I assigns BofA Securities $500 million of each maturity, establishing an aggregate $1 billion underwriting commitment and a 20% allocation of the issuance.4
Arnold & Porter confirmed that the offering was completed on 19 February 2025, identifying Bank of America Merrill Lynch among the joint book-running managers.5
The Israeli Ministry of Finance’s legal-adviser opinion, dated 19 February 2025, also identifies BofA Securities as a party to the relevant underwriting agreement.6
Israeli sovereign financing - January 2026
The State of Israel’s prospectus supplement dated 6 January 2026 documents a $6 billion offering comprising $2.25 billion due in 2031, $2 billion due in 2036 and $1.75 billion due in 2056.7
BofA Securities was allocated $450 million, $400 million and $350 million respectively, amounting to $1.2 billion in aggregate underwriting commitments.7
Israeli financial reporting described the transaction in the context of war-related expenditure and military rehabilitation, while identifying Bank of America among the participating banks.8
Across the three SEC-documented offerings, BofA Securities received $4.2 billion of aggregate underwriting allocations associated with $19 billion of sovereign issuance; these contractual allocations do not establish permanent bond ownership or that the proceeds were earmarked for specific Israeli military purchases.2, 4, 7
Israeli defence and security procurement
No public evidence identified of a direct procurement award to Bank of America by the Israeli Ministry of Defence, Israel Defense Forces, Israeli Border Police or Israel Prison Service in the materials reviewed.
No public evidence identified of Bank of America’s inclusion as an equipment or military-services supplier in an Israeli SIBAT defence-export directory.
No public evidence identified of an agreement appointing Bank of America as a manufacturer, equipment integrator or operational military-support contractor for Israeli forces.
Dual-Use Products & Tactical Variants
Business activities
Bank of America’s 2025 corporate annual-report materials identify its principal activities as financial services, while its reported Israel-related underwriting activity concerns capital-markets transactions rather than the manufacture of physical military equipment.9, 7
Militarised product lines
No public evidence identified of Bank of America manufacturing or marketing tactical vehicles, ruggedised electronics, military communications equipment, combat systems or specialised military hardware supplied to Israel.
Civilian-to-military distinction
The documented 2024–2026 transactions concern conventional sovereign debt securities, and the reviewed offering records do not identify purpose-built military technology or an Israeli military end-user contract for a Bank of America product.1, 4, 7
End-user certification and export controls
No public evidence identified of an Israeli military end-user certificate or defence export-licence application relating to equipment or software manufactured by Bank of America.
No public evidence identified of a Bank of America autonomous-targeting, fire-control or kinetic weapons-integration product designed specifically for Israeli military use.
Heavy Machinery, Construction & Infrastructure
Equipment used in occupied territories
No public evidence identified of Bank of America-branded or Bank of America-manufactured heavy machinery, vehicles or construction equipment used in Israeli settlements, military installations, separation-barrier construction or demolitions.
Direct and indirect supply
No public evidence identified of Bank of America supplying construction machinery to Israeli authorities through authorised dealers, distributors or secondary-market transactions.
Construction and engineering contracts
No public evidence identified of Bank of America holding contracts to construct, maintain or expand Israeli checkpoints, military bases, detention facilities, separation-barrier infrastructure or settlement roads.
Settlement-specific institutional involvement
No verified Bank of America-specific equipment or construction project within the West Bank, East Jerusalem or Golan Heights was established from the reviewed evidence.
Supply Chain Integration with Defence Primes
Financial relationships with weapons manufacturers
The United Nations special-procedures registry records communication OTH 86/2024, dated 20 May 2024, addressed to Bank of America concerning reported investments in RTX and Lockheed Martin, two defence manufacturers whose weapons transfers to Israel were the subject of the communication.10
The communication states that information received suggested continuing investment in these companies without demonstrated adequate heightened human-rights due diligence, while raising concerns about the use of transferred weapons in Gaza; these are allegations presented by UN experts rather than adjudicated findings.10
A related UN communications report, USA 9/2024, names Bank of America among US-based companies investing in defence manufacturers identified as transferring weapons to Israel, including companies associated with military aircraft, weapons systems and other defence equipment.11
The published communications identify the defence companies and investment-related concerns but do not supply a Bank of America-specific transaction establishing financing contractually restricted to a named Israeli weapons system.10, 11
Defence-industry board connections
Bank of America’s 2025 proxy statement identifies Linda P. Hudson as a director and former President and Chief Executive Officer of BAE Systems, Inc., serving in that executive role from October 2009 to January 2014.12
The same disclosure records her previous leadership of BAE Systems’ Land and Armaments business and earlier senior positions at General Dynamics, including its Armament and Technical Products division.12
These historical defence-industry executive appointments are [pre-2020] evidence; the proxy documents Hudson’s later Bank of America board membership but does not establish that she arranged an Israeli military contract on the bank’s behalf.12
Bank of America’s 2026 shareholder-meeting materials identify a 12-person board slate, while the official UK Companies House register records that Hudson’s Bank of America, National Association directorship ended on 4 May 2026.13, 14
Component supply
No public evidence identified of Bank of America supplying optical systems, electronic assemblies, armour materials, propulsion systems, communications modules or guidance components to Elbit Systems, Israel Aerospace Industries, Rafael or other Israeli defence manufacturers.
Joint development
No public evidence identified of military co-production, licensed weapons manufacturing, weapons-system research, or defence-specific technology-transfer agreements between Bank of America and Israeli defence companies.
Elbit Systems equity underwriting - May 2025
On 21 May 2025, BofA Securities, Inc., a Bank of America group entity, entered into an underwriting agreement with Elbit Systems Ltd., an Israeli defence manufacturer, as representative of four underwriters for a public equity offering of 1,365,450 ordinary shares at $375 per share. Elbit’s SEC Form 6-K, filed on 23 May 2025, confirms BofA’s representative role, the initial offering’s approximately $512 million gross proceeds, and the participation of J.P. Morgan Securities LLC, Jefferies LLC and Morgan Stanley & Co. LLC.15, 16
Schedule A of the executed underwriting agreement assigns BofA Securities 477,908 initial shares, representing approximately 35% of the initial offering and $179,215,500 at the public offering price. J.P. Morgan was allocated 341,362 shares, while Jefferies and Morgan Stanley were each allocated 273,090 shares. The agreement establishes an underwriter purchase price of $367.61 per share, reflecting a $7.39 underwriting discount. BofA’s initial contractual purchase commitment therefore amounted to approximately $175.7 million before any additional option shares.16
The underwriting agreement granted the syndicate an option to purchase up to 204,817 additional shares. Elbit’s 23 May 2025 Form 6-K confirms that the underwriters exercised this option in full on 22 May, generating approximately $76.8 million in additional gross proceeds. The transaction consequently involved 1,570,267 shares and $588,850,125 in aggregate gross proceeds, approximately $588.8 million. Elbit explicitly confirms that the offering closed on 23 May 2025.15, 16
Under Section 2(b) of the underwriting agreement, participating underwriters were required to purchase additional shares proportionate to their initial allocations, subject to fractional-share adjustments determined by BofA as representative. Applying BofA’s approximately 35% allocation to the 204,817 option shares implies approximately 71,686 additional shares, bringing its indicative total commitment to approximately 549,594 shares, equivalent to approximately $206.1 million at the public offering price. The reviewed agreement does not separately report each underwriter’s final executed option-share allocation, so this additional allocation is calculated rather than independently confirmed.16
Elbit’s final prospectus supplement identifies BofA Securities, J.P. Morgan, Jefferies and Morgan Stanley as joint book-running managers. It estimates approximately $575 million in net proceeds after underwriting discounts, commissions and offering expenses assuming full exercise of the option. Elbit states that the funds are intended for general corporate purposes, with management retaining broad discretion over their application. The transaction therefore establishes direct capital-markets underwriting support for an Israeli defence manufacturer, but the reviewed disclosures do not identify an earmarked Israeli military procurement programme or specific weapons system financed by the proceeds.17
Logistical Sustainment & Base Services
Military installation services
No public evidence identified of Bank of America providing catering, fuel, facilities management, vehicle maintenance, logistics, transport or other operational services to Israeli military installations.
Geographic scope
No verified Bank of America military-support service contract within the West Bank, East Jerusalem, Golan Heights, Gaza or Negev was identified.
Shipping and freight
No public evidence identified of Bank of America acting as a freight forwarder, shipping contractor or cargo-handling operator for Israeli military shipments.
Military-community programmes
The United Kingdom’s Armed Forces Covenant register records that Bank of America signed the covenant on 27 October 2015, undertaking to support British military personnel, veterans, reservists and their families; the government published the relevant register entry on 10 November 2025.18
The signed commitment is [pre-2020] in origin, although the government entry remained publicly documented in 2025; it concerns the British Armed Forces and does not establish a comparable Israeli military-support arrangement.18
The Intuit Foundation’s 2016–2017 US tax filing records a $100 matching-gift grant to Friends of the Israel Defense Forces, establishing historical receipt of an employer-related charitable matching payment from another organisation; the filing does not identify a completed matching payment by Bank of America.19
The FIDF organisation describes its mission as supporting Israeli soldiers, veterans and their families; no Bank of America-specific funding amount was established from the reviewed FIDF material.20
No public evidence identified of a verified Bank of America payment to FIDF or an Israeli reservist salary-subsidy programme operated by the bank.
Munitions, Weapons Systems & Strategic Platforms
Lethal weapons manufacturing
No public evidence identified of Bank of America manufacturing small arms, artillery systems, missiles, armoured vehicles, combat aircraft, drones, naval weapons or other lethal systems for Israel.
Munitions and precursor materials
No public evidence identified of Bank of America directly producing or supplying ammunition, explosives, propellants, warheads or specialised munitions materials for Israeli forces.
Strategic weapons programmes
The 2024 UN communication identifies Bank of America in connection with reported investments in Lockheed Martin and RTX, but does not establish that Bank of America manufactured, integrated or supplied components for a specific Israeli strategic weapons platform.10
No public evidence identified of Bank of America directly supplying equipment for Iron Dome, David’s Sling, Arrow, F-35 aircraft or Israeli armoured-vehicle programmes.
Kinetic military software
No public evidence identified of Bank of America developing or providing software purpose-built for autonomous targeting, fire-control automation, precision-guided weapons or military kill-chain decision-making.
Export Licensing, Regulatory & Legal History
Export-licence decisions
No public evidence identified of government export-licence approvals, suspensions, refusals or revocations concerning Bank of America-manufactured military equipment destined for Israeli military end-users.
UN special-procedures correspondence
The OHCHR registry identifies communication OTH 86/2024, sent to Bank of America on 20 May 2024, concerning information received about Lockheed Martin and RTX weapons transfers to Israel and the bank’s reported continued investment relationships.10
The communication raised potential human-rights and international humanitarian-law issues associated with those investments; its existence does not constitute a court judgment, regulatory penalty or finding of legal liability against Bank of America.10
Arms embargo and sanctions enforcement
No public evidence identified of a regulatory enforcement action finding that Bank of America violated an Israel-specific arms embargo through direct military-equipment exports.
Judicial proceedings
No public evidence identified of a final judicial determination establishing Bank of America’s responsibility for a specific Israeli military weapons transfer.
Continued activity after legal developments in 2024
The 11 February 2025 and 6 January 2026 sovereign underwriting records establish that BofA Securities continued entering Israeli government financing transactions after the International Court of Justice’s 19 July 2024 advisory opinion and the International Criminal Court’s November 2024 arrest warrants.4, 7
These dated underwriting transactions establish continued sovereign capital-markets activity, but do not themselves identify military procurement contracts or prove breach of an arms embargo.4, 7
Civil Society Scrutiny & Documented Investigations
UN scrutiny
Bank of America was directly named in OHCHR communication OTH 86/2024 concerning investment relationships with Lockheed Martin and RTX amid scrutiny of arms transfers to Israel.10
The broader USA 9/2024 UN communications record also includes Bank of America in a list of US-based institutional investors associated with companies exporting weapons to Israel.11
Opportunity for corporate response
The Business & Human Rights Resource Centre reported on 12 July 2024 that it had invited Bank of America to respond to UN experts’ concerns on 2 July 2024 and that the company had not responded to the invitation.21
This records a non-response to the Resource Centre’s invitation; it does not establish that Bank of America received or ignored every communication subsequently made by campaigners or regulators.21
Specialist NGO research
A June 2024 investigation publicised by FIDH examined the financial institutions backing six major weapons manufacturers associated with arms supplies to Israel: Boeing, General Dynamics, Leonardo, Lockheed Martin, RTX and Rolls-Royce.22
The report identified substantial European loans, underwriting and securities holdings associated with those companies, but its published aggregate totals cannot be attributed to Bank of America individually without bank-specific transaction data.22
The European Coordination of Committees and Associations for Palestine also publicised the June 2024 investigation, describing its underlying analysis of financial relationships with companies selling weapons systems to Israel.23
Sovereign financing in the context of the Gaza war
Contemporaneous Israeli financial reporting described the January 2026 $6 billion government bond offering as helping finance war-related expenditure and military rehabilitation, and identified Bank of America among the underwriting institutions.8
The SEC prospectus independently records the issuance and BofA Securities’ $1.2 billion contractual allocation; neither document establishes an earmarked Bank of America payment for an identified IDF weapons purchase.7, 8
Corporate disclosures and governance
Bank of America’s public investor-relations materials maintain current and historical annual reports and proxy statements, including disclosures of board membership and governance arrangements.24
The 2025 proxy documents former BAE Systems executive Linda Hudson’s defence-industry background, providing a contemporaneous corporate source for that governance relationship.12
Boycott and divestment campaigns
No verified Bank of America-specific institutional divestment decision arising from an identified Israeli military procurement contract was established.
No verified cancellation of an Israeli defence-sector financing contract in response to civil-society pressure was established.
Corporate policy and response
No public evidence identified of a Bank of America statement announcing termination of its Israeli sovereign underwriting relationships in response to the cited UN communications.
No public evidence identified of a Bank of America-specific Israeli military end-use monitoring policy covering weapons supplied by third-party manufacturers.
Footnotes
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State of Israel, Underwriting Agreement, 5 March 2024, SEC Exhibit 99.J. https://www.sec.gov/Archives/edgar/data/52749/000110465924033345/tm248330d1_ex99-j.htm ↩ ↩2
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State of Israel, $8 billion sovereign bond prospectus supplement, March 2024, SEC Form 424B5. https://www.sec.gov/Archives/edgar/data/52749/000110465924031445/tm247783-2_424b5.htm ↩ ↩2 ↩3
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Cravath, Swaine & Moore LLP, “The State of Israel’s $8 Billion Registered Notes Offering”, 26 March 2024. https://www.cravath.com/news-insights/the-state-of-israels-dollar8-billion-registered-notes-offering.html ↩
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State of Israel, Underwriting Agreement, 11 February 2025, SEC Exhibit 99.L. https://www.sec.gov/Archives/edgar/data/52749/000110465925015165/tm256980d1_ex99-l.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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Arnold & Porter, “Arnold & Porter Advises Israel on $5 Billion Sovereign Bond Offering”, 27 February 2025. https://www.arnoldporter.com/en/perspectives/news/2025/02/arnold-porter-advises-israel-on-5-billion-sovereign-bond-offering ↩
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State of Israel Ministry of Finance, Legal Adviser Opinion, 19 February 2025, SEC Exhibit 99.J. https://www.sec.gov/Archives/edgar/data/52749/000110465925015165/tm256980d1_ex99-j.htm ↩
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State of Israel, $6 billion sovereign bond prospectus supplement, 6 January 2026, SEC Form 424B5. https://www.sec.gov/Archives/edgar/data/52749/000110465926002020/tm2534616-3_424b5.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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Ynet, “Israel raises $6 billion in bond sale to fund war expenses”, January 2026. https://www.ynetnews.com/business/article/bj88gtjnzl ↩ ↩2 ↩3
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Bank of America Corporation, Annual Shareholder Meeting and 2025 Annual Report materials, 2026. https://investor.bankofamerica.com/events-and-presentations/annual-shareholder-meeting ↩
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United Nations OHCHR, Special Procedures Communication OTH 86/2024, Bank of America, 20 May 2024. https://spcommreports.ohchr.org/TmSearch/SearchCode?code=%3B+OTH+86/2024 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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United Nations OHCHR, Special Procedures Communications Report USA 9/2024, July 2024. https://spcommreports.ohchr.org/TmSearch/RelCom?code=USA+9/2024 ↩ ↩2 ↩3
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Bank of America Corporation, 2025 Proxy Statement, SEC Form DEF 14A, March 2025. https://www.sec.gov/Archives/edgar/data/70858/000119312525050578/d897280ddef14a.htm ↩ ↩2 ↩3 ↩4
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Bank of America Corporation, Annual Shareholder Meeting, 2026 board and proxy materials. https://investor.bankofamerica.com/events-and-presentations/annual-shareholder-meeting ↩
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UK Companies House, Linda Parker Hudson, official officer appointment record for Bank of America, National Association (FC002984), showing resignation on 4 May 2026. https://find-and-update.company-information.service.gov.uk/officers/iCZ2KqwHceDwGHAU2KRrGBj8fMY/appointments ↩
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Elbit Systems Ltd., SEC Form 6-K, “Report of Foreign Private Issuer - May 2025 Equity Offering and Closing”, filed 23 May 2025. https://www.sec.gov/Archives/edgar/data/1027664/000162828025027540/form6-kxclosing.htm ↩ ↩2
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Elbit Systems Ltd. and BofA Securities, Inc., “Underwriting Agreement”, dated 21 May 2025, Exhibit 1.1 to SEC Form 6-K, including Sections 2(a)–2(b), Schedule A and Schedule B-1. https://www.sec.gov/Archives/edgar/data/1027664/000162828025027540/exhibit11-esltxunderwritin.htm ↩ ↩2 ↩3 ↩4
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Elbit Systems Ltd., “Prospectus Supplement - 1,365,450 Ordinary Shares”, dated 21 May 2025, SEC Form 424B5, including “The Offering”, “Use of Proceeds” and “Underwriting”. https://www.sec.gov/Archives/edgar/data/1027664/000162828025027395/eslt-final424b5.htm ↩
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UK Government, Reserve Forces’ and Cadets’ Associations, Bank of America Armed Forces Covenant, published 10 November 2025. https://www.gov.uk/armed-forces-covenant-businesses/bank-of-america ↩ ↩2
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The Intuit Foundation, Form 990-PF, tax year ending 31 July 2017, Part XV, grants and contributions paid, page 137 (PDF page index 136), recording a $100 matching-gift grant to Friends of the Israel Defense Forces. https://990s.foundationcenter.org/990pf_pdf_archive/470/470860921/470860921_201707_990PF.pdf ↩
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Tribester Jewish Experiences, “Friends of the Israel Defense Forces (FIDF)”, organisational profile describing FIDF’s support for IDF soldiers, veterans and their families. https://www.tribester.com/organizer/friends-of-the-israel-defense-forces-fidf/ ↩
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Business & Human Rights Resource Centre, “Bank of America did not respond to urgent call by UN Experts to cease the transfer of arms to Israel”, 12 July 2024. https://www.business-humanrights.org/en/latest-news/bank-of-america-did-not-respond - to-urgent-call-by-un-experts-to-cease-the-transfer-of-arms-to-israel/ ↩ ↩2
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International Federation for Human Rights, “European financial institutions invest billions in arms companies that sell weapons to Israel”, 20 June 2024. https://www.fidh.org/en/issues/business-human-rights-environment/business-and-human-rights/european-financial-institutions-companies-weapons-israel ↩ ↩2
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European Coordination of Committees and Associations for Palestine, “The companies arming Israel and their financiers”, 20 June 2024. https://www.eccpalestine.org/the-companies-arming-israel-and-their-financiers/ ↩
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Bank of America Corporation, Annual Reports & Proxy Statements archive. https://investor.bankofamerica.com/annual-reports-and-proxy-statements ↩