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Electronic Arts DIGITAL

DIGITAL INFRASTRUCTURE AUDIT UPDATED 2026-09-22
Digital Score 0.00 /10 D Electronic Arts - BDS-1000 375
Digital 0.00

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

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Enterprise Technology Stack & Vendor Relationships

Electronic Arts Inc. is a Delaware corporation with principal executive offices in Redwood City, California, and filed its fiscal-year-2025 Form 10-K on 13 May 2025.1

EA’s FY2025 subsidiary exhibit lists Electronic Arts Israel Ltd as an Israeli-incorporated subsidiary.2 Electronic Arts Israel Ltd also remained listed in EA’s August 2026 subsidiary exhibit, after the reported 2023 closure of the Caesarea operating centre.3

The same entity appeared in EA’s FY2021 subsidiary exhibit, establishing public disclosure of the entity in 2021, 2025, and 2026, although those exhibits do not describe its ownership chain, operations, staffing, or services.2, 4, 3

EA’s U.S. Data Privacy Framework covered-entity list identifies specified U.S.-based companies including EA Delaware LLC, EA Entertainment, Electronic Arts Productions, Electronic Arts Redwood, Glu Mobile, PopCap Games, and Respawn Entertainment.5

That certification list does not name Electronic Arts Israel Ltd and is limited to entities covered by the U.S. certification, so it does not establish data-hosting, routing, or processing locations.5

Electronic Arts Limited’s FY2025 modern-slavery statement describes it as a wholly owned indirect subsidiary of Electronic Arts Inc. and states that UK operations are conducted through Electronic Arts Limited and its subsidiaries.6

On 4 August 2026, EA became a wholly owned subsidiary of Oak-Eagle AcquireCo, Inc. following the merger of Oak-Eagle MergerCo, Inc. into EA; EA’s public shareholders’ shares were cancelled for $210 per share and EA stock ceased trading.7, 8 The European Commission found that PIF acquired sole control of EA, while Silver Lake-managed and A Fin Management LLC/Affinity Partners-managed vehicles held non-controlling minority interests.9

Surveillance, Biometrics & Retail Technology

No public evidence identified.

The reviewed corporate filings, privacy-certification material, locations page, modern-slavery statement, transaction records, and contemporaneous reporting do not document EA provision of surveillance systems, biometric technology, retail-security technology, or related services in Israel or the occupied Palestinian territory.1, 2, 5, 10, 6, 11, 12, 7, 3, 9

No public evidence identified of an EA facility in internationally recognized occupied territory within the reviewed materials.2, 10, 11, 12, 3

The documented Israeli operational reporting concerns a Caesarea R&D and cloud-development centre, rather than surveillance, biometrics, or retail technology.11, 12

The reviewed sources identify Affinity-linked transactions involving S Shlomo Holdings Ltd.’s car-and-credit division and Phoenix Financial Ltd., an Israeli financial-services company, but do not describe either as providing surveillance, cyber, biometric, intelligence, military-AI, cloud/data-processing, or automated-control technology.13, 14

No public evidence identified in the reviewed sources that either identified investment supplied such capability to Israeli state, military, security, occupation, or settler actors, or caused documented digital harm to Palestinians.13, 14

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

CTech reported in April 2023 that EA’s Caesarea R&D centre had been established following EA’s 2018 acquisition of GameFly’s Israeli assets and employees, and that the centre developed a cloud-based game-streaming service for EA.11

Globes reported contemporaneously that EA confirmed closure of the Caesarea development centre and its internal cloud-development activities there.12

The reports describe the Caesarea activity as operationally discontinued in 2023, while EA’s FY2025 and August 2026 subsidiary exhibits continued to list Electronic Arts Israel Ltd.2, 11, 12, 3

EA’s careers-locations page, accessed in September 2026, lists offices in the Americas, Asia-Pacific, and Europe but does not list an Israeli office.10

The absence of an Israeli office from that locations page does not establish the absence of Israeli legal presence, contractors, remote personnel, data infrastructure, or data processing.2, 10, 3

No public evidence identified of a current EA data centre, cloud region, data-routing function, Israeli sovereign-cloud participation, government cloud contract, or data-residency arrangement in the supplied research materials.1, 2, 5, 10, 11, 12, 3

Defence, Intelligence & Security Sector Technology Relationships

No public evidence identified of direct EA defence, intelligence, military, police, security-sector, or foreign-military-sales contracting in the supplied research materials.1, 2, 15, 6, 11, 12, 7, 3, 9

The available Israeli operational reporting concerns game-streaming and internal cloud-development work, not a documented defence, intelligence, or security-sector technology relationship.11, 12

No public evidence identified in reviewed transaction, portfolio, regulatory, and company records of an Affinity investment in a named Israeli military-, defence-, surveillance-, cyber-, biometric-, intelligence-, or military-AI company.16, 13, 14, 17

The identified Israel-linked Affinity transactions were a reported September 2023 agreement for a 15% minority stake in S Shlomo Holdings Ltd.’s car-and-credit division and a reported 2024–25 investment in Phoenix Financial Ltd., comprising an initial 4.95% stake and regulatory approval to acquire a further 4.95%.13, 14 The reviewed sources do not describe either company as providing the specified digital or defence products.13, 14

A 2022 report stated that two Israeli technology companies had reportedly been selected, but did not name them, identify a completed investment, or identify their sectors; their products and downstream beneficiaries therefore cannot be verified.17

EA’s FY2025 proxy identified Andrew Wilson as Board Chair and CEO and named Kofi A. Bruce, Rachel A. Gonzalez, Jeffrey T. Huber, Talbott Roche, Richard A. Simonson, Luis A. Ubiñas, Heidi J. Ueberroth, and Andrew Wilson as board nominees.15 At the August 2026 closing, the seven non-management directors listed in EA’s Form 8-K resigned, while EA’s closing announcement identified Andrew Wilson as Chairman and CEO.7, 8

Targeted review of Andrew Wilson, Laura Miele, Kofi A. Bruce, and Jeffrey T. Huber found no public evidence of a personal investment, board role, or family-office interest in Israeli surveillance, cyber, AI, signals-intelligence, or military-technology firms.15 That limited finding does not extend to every pre-closing director, executive, historical founder Trip Hawkins, Vanguard, or post-closing investor representatives.15

AI, Algorithmic & Autonomous Systems

No public evidence identified of EA supplying autonomous systems, military AI, intelligence-analysis systems, or algorithmic-surveillance technology in the supplied research materials.1, 2, 15, 5, 6, 11, 12, 7, 3, 9

The reported Caesarea work was described as cloud-based game-streaming and internal cloud development, rather than AI, autonomous, surveillance, or military systems work.11, 12

The supplied material does not establish the present data-processing role, if any, of Electronic Arts Israel Ltd.2, 5, 10, 11, 12, 4, 3

No public evidence identified that EA, Parent, PIF, Affinity, or Silver Lake provides technology to Israeli settlements, Israeli state security institutions, the IDF, or occupied-territory operations within the records reviewed.16, 7, 3, 9, 13, 14, 17

Technology Ecosystem & R&D Footprint

Electronic Arts Israel Ltd remained listed in EA’s FY2025 and August 2026 subsidiary exhibits despite contemporaneous reporting that EA closed its Caesarea development centre in 2023.2, 11, 12, 3

Globes reported that the Caesarea office had 63 employees at the time of closure, while CTech reported that dozens of employees were laid off.11, 12

Those employee figures are contemporaneous press reporting rather than an EA regulatory filing, and the available filings do not confirm current headcount or operational function for Electronic Arts Israel Ltd.2, 11, 12, 3

EA’s locations page does not list an Israeli office, while its FY2025 and August 2026 subsidiary exhibits identify an Israeli-incorporated entity.2, 10, 3

No primary Israeli Companies Authority extract, Israeli tax or VAT record, or Israeli employment filing was retrieved in the supplied research materials.2, 3

No public evidence identified of present facilities, employment activity, data processing, data residency, data routing, cloud operations, or government customers of Electronic Arts Israel Ltd after the reported 2023 closure.10, 11, 12, 3

Civil Society Scrutiny & Regulatory History

The supplied local pre-scan found no mention of Electronic Arts in the specified OHCHR settlement databases, A/HRC/59/23, or the listed NGO reports.2, 11, 12

That result is document-scoped and does not establish that no external scrutiny, regulatory matter, or civil-society allegation exists outside the reviewed documents.2, 11, 12

EA’s FY2025 proxy reported Vanguard Group Inc. as holding 11.60% of outstanding shares as of 17 June 2025, with Public Investment Fund at 9.87%, BlackRock at 8.91%, and State Street at 5.97%.15 These public-company holdings ceased to describe EA’s ownership after the August 2026 merger.7

The 28 September 2025 merger agreement identified Affinity Partners Fund I LP, Affinity Partners Parallel Fund I LP, and four named Fund I co-investment vehicles as Affinity guarantors and equity-financing participants, alongside PIF and Silver Lake affiliates.16 The agreement does not disclose the beneficial ownership of each Affinity vehicle or their post-closing EA governance rights.16

A 2024 Senate Finance Committee letter cites A Fin Management LLC’s 31 March 2023 SEC Form ADV Part 2A as stating that A Fin Management LLC and its investment-advisory affiliates operate as “Affinity,” and that Jared Kushner is its sole owner.18 A December 2024 congressional letter repeats that Form ADV-based description and reports an investment-management relationship with PIF; the letters are congressional statements and requests for investigation, not adjudications or findings of wrongdoing.19

The public post-closing records establish that Parent wholly owns EA and that PIF has ultimate sole control, while characterizing Affinity’s interest as non-controlling.7, 9 no public evidence identified of Affinity’s exact EA equity percentage, voting arrangements, board-designation rights, shareholder agreement, beneficial owners of the six Affinity funds, board seat, independent power to direct EA, or controlling rights over EA.16, 7, 9

Kushner’s sole ownership of the Affinity adviser/manager is supported at the cited 2023 Form ADV date, while the EA transaction was signed on 28 September 2025 and closed on 4 August 2026.16, 7, 18 no public evidence identified that Kushner personally held EA shares, held an EA directorship, or possessed a disclosed EA governance right.16, 7, 9, 18

Footnotes

  1. https://www.sec.gov/Archives/edgar/data/712515/000071251525000022/ea-20250331.htm ↩ ↩2 ↩3 ↩4 ↩5

  2. https://www.sec.gov/Archives/edgar/data/712515/000071251525000022/ex-211subsidiariesofthereg.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16

  3. https://www.sec.gov/Archives/edgar/data/712515/000162828026033617/ex-211subsidiariesofthereg.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16

  4. https://www.sec.gov/Archives/edgar/data/712515/000071251521000064/ex-211subsidiariesofthereg.htm ↩ ↩2

  5. https://tos.ea.com/legalapp/dpfcoveredentities/US/en/PC/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  6. https://media.contentapi.ea.com/content/dam/eacom/en-gb/legal/electronic-arts-limited-modern-slavery-statement.pdf ↩ ↩2 ↩3 ↩4

  7. https://www.sec.gov/Archives/edgar/data/712515/000114036126031157/ef20079099_8k.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  8. https://www.sec.gov/Archives/edgar/data/712515/000114036126031157/ef20079099_ex99-1.htm ↩ ↩2

  9. https://ec.europa.eu/competition/mergers/cases1/202637/M_12213_479.pdf ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  10. https://www.ea.com/careers/locations ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8

  11. https://www.calcalistech.com/ctechnews/article/rjydfvaz3 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17

  12. https://en.globes.co.il/en/article-games-giant-ea-closes-israel-development-center-1001444241 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15 ↩16 ↩17

  13. https://news.bloomberglaw.com/mergers-and-acquisitions/kushners-saudi-backed-affinity-to-acquire-stake-in-israeli-firm ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  14. https://news.bloomberglaw.com/mergers-and-acquisitions/kushners-affinity-gets-nod-to-double-stake-in-israels-phoenix ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  15. https://www.sec.gov/Archives/edgar/data/712515/000130817925000556/ea014143-def14a.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  16. https://www.sec.gov/Archives/edgar/data/712515/000114036125036416/ef20056167_defa14a.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  17. https://www.timesofisrael.com/riyadh-to-invest-millions-in-israeli-tech-via-jared-kushners-new-fund-report/amp/ ↩ ↩2 ↩3

  18. https://www.finance.senate.gov/imo/media/doc/chairman_wyden_to_fin_management_on_kushner_firm_paymentspdf.pdf ↩ ↩2 ↩3

  19. https://oversightdemocrats.house.gov/imo/media/doc/Letter%20to%20DOJ%20on%20Kushner%20-%20FARA%20(Wyden%20-%20Raskin)%20final.pdf ↩