Bank of America POLITICAL

Target: Bank of America Corporation Domain: Political Research date: 23 October 2026 Scope: Corporate communications, Israeli operations, institutional relationships, political financing, governance, and executive conduct.

Corporate Communications & Public Stance

Official statements and internal communications

In November 2023, Morocco World News reported that Bank of America had circulated an employee statement describing the 7 October attacks in Israel as horrific acts of terrorism and expressing concern about their impact on communities worldwide. The publication also reported objections from some employees to the statement’s treatment of Palestinian civilian suffering. The report is a secondary account of an internal communication. ¹

Executive commentary

In August 2023, Bernard Mensah, then identified as Bank of America’s President of International, expressed confidence in Israel’s economic prospects, referring to the country’s technology sector, human capital, and research and development investment. The comments concerned commercial prospects before the October 2023 escalation. ²

Market framing

Bank of America’s current international locations directory lists Tel Aviv among its global financial-services locations, with an office at the Azrieli Center. The company’s presentation places Israel within its international commercial banking and investment-services network. ³

The bank’s regulatory disclosure identifies Merrill Lynch Israel Ltd. as an Israeli subsidiary based in Tel Aviv. ⁴

Comparative public posture

The reviewed November 2023 communication specifically addressed attacks in Israel, while the cited employee-reaction report described objections concerning its treatment of Palestinians. The reviewed evidence does not establish a comprehensive comparison of the bank’s official statements concerning Israel-Palestine, Ukraine, Black Lives Matter, and COVID-19. ¹

Post-2024 public communications

No public evidence identified of an independently verified, comprehensive Bank of America corporate policy statement addressing the July 2024 ICJ advisory opinion or November 2024 ICC warrants.

Bank of America’s official international locations directory, published on its own business and institutional banking website, contains an explicit market-facing statement: “As one of the world’s leading financial institutions, Bank of America has operations in more than 35 countries.” It invites corporate and institutional customers to discover its business solutions, research and insights to support growth. The same presentation includes Israel under “Europe, Middle East & Africa” and identifies Tel Aviv as an operating location. A further statement offers comprehensive advisory and financial solutions across markets, industries and locations. These statements constitute Bank of America’s own commercial communication to prospective institutional clients, whereas the Tel Aviv address and telephone number independently establish only contact information. The commercial statements are global rather than specifically directed at Israel or expressive of support for Israeli government policies. ³

The official directory remained publicly accessible with its Israel listing and associated commercial presentation on 23 October 2026. Its continued availability on that date establishes current publication, but the reviewed page does not display a dated publication or revision history establishing when the wording was introduced or whether it remained unchanged throughout the intervening years. No independently dated archive or corporate republication establishing uninterrupted use of the exact wording was identified in the reviewed material. ³

Operations in Occupied or Contested Territories

Territorial presence

Bank of America’s official directory currently lists an office at 1 Azrieli Center, Round Tower, 35th Floor, Tel Aviv, Israel. ³

The company’s 2024 Form 10-K subsidiary exhibit, filed in February 2025, lists Merrill Lynch Israel Ltd., Tel Aviv, among its subsidiaries. ⁴

No public evidence identified of a Bank of America-owned office, branch, automated teller machine, or documented service contract physically located within an Israeli settlement in the occupied Palestinian territories.

State financing through securities underwriting

On 5 March 2024, the State of Israel published an SEC-filed pricing term sheet for $8 billion of sovereign bonds. The offering comprised $2 billion due in 2029, $3 billion due in 2034, and $3 billion due in 2054. BofA Securities was one of four joint bookrunners, each identified with a 25% allocation. ⁵

On 11 February 2025, BofA Securities entered into an underwriting agreement with the State of Israel for a $5 billion sovereign bond offering, comprising two $2.5 billion tranches due in 2030 and 2035. The agreement also names Citigroup Global Markets, Deutsche Bank, Goldman Sachs, and J.P. Morgan Securities as underwriters. ⁶

On 6 January 2026, BofA Securities entered into another Israeli sovereign underwriting agreement covering $6 billion of bonds maturing in 2031, 2036, and 2056. ⁷

The January 2026 SEC prospectus assigns BofA Securities principal underwriting commitments of $450 million, $400 million, and $350 million across the three maturities, respectively, totalling $1.2 billion. These are contractual underwriting allocations rather than disclosed charitable contributions or purchases of military equipment. ⁸

International legal and regulatory scrutiny

A United Nations Special Procedures communication dated 20 May 2024, reference OTH 86/2024, was directed to Bank of America. It recorded concerns concerning the bank’s investments in RTX and Lockheed Martin, whose weapons transfers to Israel were the subject of allegations, and questioned the adequacy of heightened human-rights due diligence. The communication represents UN experts’ concerns rather than a judicial determination of Bank of America’s legal responsibility. ⁹

On 12 July 2024, the Business & Human Rights Resource Centre reported that Bank of America had not responded to its 2 July invitation concerning UN experts’ call for an end to arms transfers to Israel. ¹⁰

No verified inclusion of Bank of America itself in the UN OHCHR settlement-business database was established.

Civil-society investigations and boycott activity

In 2025, BankTrack reported research identifying Bank of America among seven financial institutions involved in underwriting Israeli sovereign bonds after 7 October 2023. The investigation characterised the financing as supporting Israel’s capacity to fund its military campaign; that characterisation is attributable to the researchers. ¹¹

In June 2026, Novara Media reported that Bank of America remained among international banks involved in Israeli sovereign underwriting after Barclays and BNP Paribas had withdrawn from further deals, according to the reporting and referenced research. ¹²

A BDS movement chronology records that, as of 14 February 2024, Bank of America Corporation had disclosed a reduction exceeding 50% in its Elbit Systems shareholding compared with November 2023. The chronology does not establish that activist pressure caused the reduction or that every group entity had exited its exposure. ¹³

Company response

The Business & Human Rights Resource Centre specifically recorded a non-response to its July 2024 invitation concerning UN experts’ allegations. No separate verified formal response by Bank of America to the 2025 BankTrack sovereign-underwriting investigation was identified. ¹⁰

Internal Governance, Content & Retail Policies

Employee relations and political expression

November 2023 reporting described employee objections to Bank of America’s internal statement about the attacks in Israel and its perceived treatment of Palestinian suffering. The report did not establish that employees had been dismissed, formally disciplined, or subjected to litigation for pro-Palestinian expression. ¹

No public evidence identified of verified Bank of America dismissals, disciplinary proceedings, union litigation, or a specific HR policy restricting lawful pro-Palestinian employee speech.

Shareholder governance

Bank of America’s 2026 proxy statement describes its governance procedures, director elections, shareholder proposals, and board recommendations. The filing establishes the formal shareholder-proposal process but does not, in the reviewed material, establish targeted suppression of an Israel-Palestine human-rights resolution. ¹⁴

No public evidence identified of an independently verified Bank of America decision to exclude an Israel-Palestine shareholder proposal specifically because it addressed Palestinian rights.

Platform and editorial policies

No public evidence identified of Bank of America operating a social-media moderation platform or implementing a documented algorithmic policy suppressing Palestinian content.

No public evidence identified of a Bank of America-operated cartographic platform altering the representation of Palestine, settlements, or Israeli military installations.

Retail and supply-chain policies

No public evidence identified of Bank of America retail-product labelling practices, settlement-origin consumer-product classifications, or regulatory action concerning the sourcing of goods produced in Israeli settlements.

Charitable matching and reservist policies

No public evidence identified establishing that Bank of America’s employee donation-matching programme specifically matched payments to the IDF, Friends of the IDF, settlement organisations, or Israeli military-welfare bodies.

No public evidence identified of a verified Bank of America policy subsidising Israeli military reservist salaries or granting military-specific corporate financial assistance beyond any generally applicable legal employment obligations.

Brand Heritage & State Partnerships

Corporate identity and branding

Bank of America’s current governance materials identify Brian Moynihan as Chair and Chief Executive Officer and describe the company as a diversified financial-services institution. The company’s public description of its leadership and business activities does not identify an Israeli state-security or military mandate. ¹⁵

Israeli institutional recognition

Bank of America’s corporate awards directory identifies recognition from American Friends of Magen David Adom for corporate leadership and longstanding efforts to combat antisemitism. The directory describes Magen David Adom as Israel’s national emergency-response, blood-services, and disaster-relief organisation. The award listing does not disclose a donation amount or military-directed payment. ¹⁶

The same awards directory records recognition from American Friends of Rabin Medical Center through a Yitzhak Rabin Lifetime Corporate & Civic Responsibility Leadership Award, associated with the bank’s support for communities and the Israeli medical institution’s healthcare work. The listing does not specify the underlying contributions or payment dates. ¹⁶

Commercial representation in Israel

The bank’s international office directory and regulatory subsidiary disclosure establish its current Tel Aviv commercial presence through the broader Bank of America and Merrill Lynch group. ^{3, 4}

State cultural sponsorship and military branding

No public evidence identified of a verified Bank of America corporate sponsorship specifically designated as a Brand Israel public-diplomacy campaign.

No public evidence identified of Bank of America marketing itself through Israeli military heritage or Israeli intelligence-service origins.

No public evidence identified of a corporate sponsorship agreement with an Israeli settlement municipality or settlement-promotion event.

Lobbying, Advocacy, Financing & Logistics

Political contributions

Bank of America’s published political-activities policy states that its PAC is supported by voluntary employee contributions and that the company may pay permitted administrative costs. The policy distinguishes PAC activity from corporate contributions directly to candidates and political parties. ¹⁷

Federal Election Commission records identify the Bank of America Corporation State and Federal PAC under committee identifier C00043489 and provide its federal reporting history. These filings document regulated political activity without, by themselves, establishing an Israel-Palestine-specific lobbying objective. ¹⁸

No public evidence identified of a verified corporate payment explicitly earmarked for lobbying in support of Israeli settlements or opposition to Palestinian self-determination.

No public evidence identified of a verified Bank of America corporate donation directly funding an anti-BDS legislative campaign.

Sovereign financing - March 2024

The March 2024 SEC pricing term sheet identifies BofA Securities as a 25% joint bookrunner on an $8 billion State of Israel sovereign bond transaction. The offering’s stated net proceeds before expenses were approximately $7.83 billion across its three tranches. ⁵

Sovereign financing - February 2025

The February 2025 executed underwriting agreement identifies BofA Securities as a contractual underwriter of Israel’s $5 billion sovereign issuance. This participation occurred after both 19 July 2024 and the November 2024 ICC arrest-warrant milestone identified for this audit. ⁶

Sovereign financing - January 2026

The January 2026 executed underwriting agreement names BofA Securities among five underwriters of Israel’s $6 billion bond transaction, providing direct documentary evidence of continuing participation after the 2024 international legal developments. ⁷

The SEC prospectus specifies that BofA Securities was allocated $1.2 billion of principal underwriting commitments across the three January 2026 tranches. The record identifies securities-underwriting obligations; it does not establish that the bank donated $1.2 billion to Israel or earmarked those proceeds for a particular military operation. ⁸

Civil-society characterisation of financing

BankTrack’s 2025 research linked Israeli sovereign-debt issuance to increased government financing requirements during the Gaza war and identified Bank of America among participating underwriters. Its characterisation of the financing’s consequences remains an attributed civil-society assessment. ¹¹

Investments in defence manufacturers

The May 2024 UN Special Procedures communication concerning Bank of America specifically raised the issue of investments in RTX and Lockheed Martin and sought responses regarding due diligence and possible connections to arms transfers to Israel. ⁹

A BDS chronology reports that Bank of America’s disclosed holdings of Elbit Systems shares had declined by more than 50% between November 2023 and February 2024. The cited chronology does not establish whether that reduction represented a comprehensive withdrawal across all investment-management and client-held portfolios. ¹³

Military and settlement donations

No public evidence identified of a verified direct Bank of America corporate donation to the IDF, Friends of the IDF, JNF/KKL, Regavim, Im Tirtzu, or a named Israeli settlement organisation.

Crisis asset mobilisation

No public evidence identified establishing that Bank of America transferred vehicles, aircraft, military supplies, technology infrastructure, or free operational services directly to the Israeli military during the Gaza conflict.

Humanitarian contributions

The company’s awards directory establishes recognition from organisations supporting Israeli emergency medical services and healthcare, but the reviewed award descriptions do not document the monetary value, beneficiary restrictions, or military purpose of any underlying contributions. ¹⁶

February 2025 - no public evidence identified: the executed 11 February underwriting agreement was examined for an attributable BofA Securities statement endorsing Israeli government policy, legitimating military operations, supporting territorial claims, or advocating a political position. The document identifies the State of Israel as issuer and BofA Securities among the contractual underwriters. Its provisions concern securities issuance, purchase obligations, representations, distribution arrangements and related financial and legal responsibilities. The identified wording does not establish a separate political endorsement, named political beneficiary of corporate advocacy, or political communications channel attributable to Bank of America. ⁶

January 2026 - the State of Israel’s 6 January prospectus supplement publicly identifies BofA Securities as a joint book-running manager. Its underwriting section states that participating institutions agree, subject to contractual conditions, to purchase allocated bonds and offer them to the public at the specified offering price. The beneficiary of the securities financing is the State of Israel, and the documented distribution channel is the sovereign bond offering to investors. This establishes attributable commercial participation in public securities distribution, including the presentation of Israel’s debt to prospective investors. It does not independently establish political advocacy or an endorsement of Israeli government policies by BofA Securities. The prospectus is issued by the State of Israel; the bank’s identification as a bookrunner does not establish authorship of the sovereign issuer’s statements. ^{7, 8}

January 2026 - no public evidence identified: examination of the executed underwriting agreement and associated prospectus supplement did not identify an independently attributable BofA Securities political endorsement, public statement legitimating Israeli military operations, or advocacy communication separate from its contractual securities-distribution role. The prospectus expressly describes the underwriters as financial institutions performing commercial and investment-banking activities and acknowledges that they may express independent research views. That general disclosure establishes no particular political statement concerning Israel. ^{7, 8}

Corporate Structure & Primary Mission

Corporate governance

Bank of America’s current governance disclosures identify Brian T. Moynihan as Chair and Chief Executive Officer and Lionel L. Nowell III as Lead Independent Director. The company presents itself as a publicly traded financial-services corporation governed through directors and shareholders. ¹⁵

The 2026 proxy statement documents director elections, shareholder voting, governance matters, and executive compensation. It provides evidence of an ordinary publicly listed corporate governance structure. ¹⁴

Operating entities

Bank of America’s regulatory subsidiary disclosure lists multiple financial-services entities, including Bank of America Europe D.A.C., BofA Securities Europe S.A., Merrill Lynch International, and related subsidiaries. These disclosures describe a multinational corporate group. ¹⁹

The company’s February 2025 Form 10-K subsidiary exhibit identifies Merrill Lynch Israel Ltd. as an Israeli group company. ⁴

Primary corporate mission

The company’s published governance disclosures describe banking, financial intermediation, investment services, shareholder oversight, and responsible growth. No explicit founding mandate to advance Israeli state geopolitical objectives is identified in these reviewed documents. ^{15, 14}

State ownership and control

No public evidence identified of an Israeli state-held golden share, Israeli government ownership control, or a constitutional requirement directing Bank of America to advance Israeli geopolitical policy.

Executive & Leadership Footprint

Brian T. Moynihan - Chair and Chief Executive Officer

Bank of America’s current board directory identifies Brian Moynihan as Chief Executive Officer since January 2010 and Chair since October 2014. It lists his leadership affiliations with the Bank Policy Institute, Financial Services Forum, Business Roundtable, and other business and civic organisations. ¹⁵

No public evidence identified of a verified personal donation by Moynihan to the IDF, Friends of the IDF, Israeli settlement organisations, or Israeli military-welfare funds.

No public evidence identified of a verified personal board position held by Moynihan in AIPAC, the JNF, Regavim, or an Israeli settlement-advocacy organisation.

Bernard Mensah - International leadership

In August 2023, Bernard Mensah was identified as Bank of America’s President of International and publicly discussed Israel’s economic strengths, including technology and research and development. His comments constitute an attributable senior-executive commercial assessment concerning Israel before October 2023. ²

No public evidence identified of a verified personal military-welfare donation, settlement-organisation directorship, or post-October 2023 military-support statement by Mensah.

Lionel L. Nowell III - Lead Independent Director

Bank of America’s current governance directory identifies Lionel Nowell III as Lead Independent Director and lists his directorship at Textron Inc., among other corporate roles. The directory establishes a board-level association with an industrial and aerospace company but does not establish that Nowell personally approved arms transfers to Israel or that Bank of America financed such transfers through that affiliation. ¹⁵

No public evidence identified of a verified personal donation by Nowell to an Israeli military or settlement organisation.

Jim Fitterling - Director

Bank of America’s governance directory identifies Jim Fitterling as a director appointed in October 2026 and records his previous executive leadership at Dow and board experience involving 3M. The listed corporate affiliations do not independently establish any Israel-Palestine political advocacy or military-financing activity by Fitterling. ¹⁵

No public evidence identified of a verified personal Israeli military donation or settlement-promotion role connected with Fitterling.

Executive-linked foundations and personal donations

No public evidence identified establishing that a currently controlling Bank of America executive, director, or shareholder holding at least 10% of the company personally funded the IDF, Friends of the IDF, JNF/KKL, or a named settlement organisation through a disclosed personal or family foundation.

Executive advocacy after July–November 2024

No public evidence identified of a verified personal statement by Bank of America’s named controlling executives explicitly endorsing settlement expansion, calling for the annexation of occupied Palestinian territory, or directing corporate resources to Israeli military operations after the July and November 2024 international legal milestones.

Bank of America’s official executive biography confirms that Bernard Mensah became President of International in 2020, joined the executive management team, and held responsibility for developing and executing the bank’s international strategy. His remit encompassed corporate, commercial and investment banking, research, markets and institutional-client relationships. This independently establishes his senior corporate capacity relevant to the August 2023 Israel remarks. The original interview, published by Globes on 2 August 2023, identifies him in that capacity and records him discussing Bank of America’s economic forecasts, Israeli technology-sector prospects, and international banking strategy. His statement that the bank’s Israeli presence was a critical element of its international strategy provides an explicit connection between the interview and his corporate responsibilities. ^{20, 21}

The attributable communications channel was an exclusive interview with the Israeli business newspaper Globes, conducted by journalist Aharon Katz and published on 2 August 2023. The publication addressed an external business-news readership and discussed opportunities for Israeli companies seeking access to the United States. Mensah described the US market as critical to Israeli companies’ growth and identified support from large US banks as one possible means of expansion. This establishes external commercial communication directed through an identifiable Israeli media outlet. The available article does not identify individual readers, audience demographics, circulation attributable to the interview, or attendees at any event where the Israel-specific remarks were delivered. Mensah’s separate description of an annual technology conference does not establish that the reported Israel remarks were delivered to that conference’s participants. ^{21, 2}

The Globes interview also attributes to Mensah a reference to an early July 2023 Bank of America research report discussing Israeli market volatility, shekel depreciation, and possible interest-rate consequences. The reported research assessment indicates that his commercial commentary drew upon institutional analysis rather than solely personal impressions. However, the underlying research publication was not independently retrieved in this review, and the newspaper’s description does not establish corporate approval of every interview statement or subsequent adoption of his remarks as an official political position. ²¹

August 2023–October 2026 - no public evidence identified: the reviewed official executive biography, original Globes interview and subsequent JNS coverage do not establish a Bank of America corporate press release adopting Mensah’s Israel-specific remarks, a formal executive-management or board endorsement, or continuing republication of those remarks by Bank of America. JNS reproduced the substance of the interview on 2 August 2023, establishing contemporaneous third-party dissemination. The continuing availability of that reporting and Mensah’s corporate biography does not independently establish sustained corporate republication or an institutional political campaign. ^{20, 21, 2}