PayPal POLITICAL

Corporate Communications & Public Stance

• In March 2022, then-President and CEO Dan Schulman stated that PayPal supported Ukraine, condemned Russia’s military aggression, suspended services in Russia, and launched consumer-giving campaigns for Ukraine-related humanitarian relief.¹

• PayPal subsequently announced expanded peer-to-peer payments for Ukrainian customers, fee-related relief measures, and fundraising, and reported in its August 2023 update that PayPal and charity partners had raised more than US$600 million for Ukraine-relief organizations.²

• No public evidence identified in the reviewed corporate-news and Israel legal materials of an equivalent PayPal statement, Gaza-relief programme, or Palestinian product-access initiative specific to Israel–Palestine.^{3, 4}

• The 2026 proxy included a shareholder proposal seeking a financial-services non-discrimination policy for conflict zones that expressly referred to Palestine, while identifying the proposal’s factual assertions as those of its proponents.⁵

• In its opposition statement, PayPal said market-entry and product-availability decisions consider customer need, financial impact, competition, costs, risk, regulatory and compliance requirements, and partner relationships.⁵

• No public evidence identified in the reviewed materials that PayPal Holdings or PayPal Inc. publicly promoted the 2024 Friends of the Israel Defense Forces grant, a FIDF-specific donor account, or a policy specifically addressing FIDF, Thank Israeli Soldiers, IDF-related charities, settlement organizations, or Palestinian humanitarian charities.^{5, 6, 7}

Operations in Occupied or Contested Territories

• PayPal’s Israel user agreement identifies PayPal Israel Payments Services Ltd., company number 516478872, as the provider of PayPal services in Israel and states that it is licensed and regulated by the Israel Securities Authority as a payment-service provider.³

• PayPal’s 2026 migration materials state that the Israeli provider changed from PayPal Pte. Ltd. to PayPal Israel Payment Services Limited, give the local entity’s address as Yigal Alon 98, Tel Aviv-Yafo 6789141, Israel, and state that it operates under direct Israel Securities Authority supervision.^{4, 8}

• The agreement requires individual Israeli-account holders to be resident in Israel and business-account holders to be organized, operating, or resident in Israel.³

• PayPal’s Israel materials establish service provision in Israel but do not identify service availability, premises, or eligibility treatment for the West Bank, East Jerusalem, the Golan Heights, or settlements.^{3, 4}

• 7amleh reported in May 2026 that Palestinians in the West Bank and Gaza were excluded from PayPal while the service remained available to Israeli citizens, including West Bank settlers; this is a civil-society organization’s reported finding rather than a PayPal statement or independently conducted eligibility test.⁹

• A 2021 report described substantially similar allegations by Palestinian activists and reported that PayPal did not respond to repeated requests for comment; this is contemporaneous news reporting rather than a PayPal admission or official legal finding.¹⁰

• A June 2023 UN Committee newsletter reported that eleven Members of Congress had written to PayPal urging it to open services to Palestinians in the occupied territory.¹¹

• No new primary PayPal territorial-eligibility record, settlement-address test, or Palestinian financial-regulatory record was located in the reviewed materials.^{3, 5, 12, 13}

• No public evidence identified of a named PayPal branch, contract, reseller, subsidiary, or facility physically located in a West Bank settlement, East Jerusalem settlement, or the Golan Heights.^{3, 4, 5, 14, 15}

• The supplied document-scoped review reported no PayPal mention in the specified local copies of the 2023 and 2025 OHCHR settlement-business materials, the UN Special Rapporteur’s A/HRC/59/23 report, and the listed Amnesty, Human Rights Watch, Al-Haq, Who Profits, PAX, BankTrack, and BDS materials; this does not establish absence from other editions, databases, investigations, or records.^{12, 13}

Internal Governance, Content & Retail Policies

• No public evidence identified in the reviewed sources of PayPal employee discipline, employment litigation, union disputes, or platform-content enforcement specifically concerning Israel–Palestine.^{5, 14, 15}

• No public evidence identified of a PayPal-specific regulatory inquiry, academic moderation study, or substantiated finding concerning suppression of Israel–Palestine-related content.^{3, 5, 14}

• The 2026 conflict-zone shareholder proposal was included in PayPal’s proxy and put to a shareholder vote, rather than being described in the reviewed proxy as excluded.⁵

• No public evidence identified of PayPal retail-product labeling, sourcing, or settlement-origin categorization practices.^{3, 4}

• PayPal Giving Fund’s donor terms state that donors may recommend grants, but recommendations are advisory and non-binding; the Fund retains exclusive legal control and may redirect funds when it cannot follow a recommendation.⁶

• The Fund’s nonprofit agreement states that donations are made to the Fund rather than the recipient and that the Fund exercises discretion in making grants.¹⁶

• The Fund’s Donor Account Policy defines donor accounts as donor-advised funds to which an individual or corporation has donated pending a recommendation by the donor or adviser; for a company-controlled account, the company must authorize recommenders in writing.¹⁷

• The reviewed policies do not identify a PayPal Inc.-controlled account, an authorized individual, or PayPal Inc. involvement in the 2024 FIDF grant.^{6, 17}

Brand Heritage & State Partnerships

• No public evidence identified of PayPal using Israeli military heritage, defence-sector ties, or state-security origins in its branding.^{3, 4}

• No public evidence identified of an Israel–Palestine-specific state partnership, state honour, academic partnership, or state-backed cultural sponsorship by PayPal.^{3, 4, 5}

• PayPal’s proxy describes its stated mission as to “revolutionize commerce globally,” and the bounded review did not establish a charter, ownership, or corporate-mission mandate linked to Israeli state infrastructure or geopolitical objectives.⁵

• No public evidence identified of state ownership, a state-held golden share, or founding-document language establishing an Israeli state-geopolitical or state-infrastructure mission; no Delaware charter or historical founding-document review was completed.^{5, 18}

Lobbying, Advocacy, Financing & Logistics

• PayPal’s 2025 political-engagement policy states that political contributions, lobbying expenditures, and government-official interactions are overseen by the Board’s Governance Committee, the Chief Risk Officer, and Global Government Relations.¹⁹

• The policy states that the PayPal PAC reports donations quarterly to the Federal Election Commission and that PayPal files federal lobbying reports quarterly.¹⁹

• The policy further states that PayPal does not make independent expenditures directly supporting or opposing electoral candidates and limits corporate political contributions to lawful U.S. state and local activity.¹⁹

• No public evidence identified in the reviewed sources of PayPal corporate payments or sponsorships to FIDF, JNF/KKL, IDF-related funds, settlement organizations, AIPAC, CFI, USISTF, or named anti-BDS organizations.^{5, 19, 20}

• The absence finding is not comprehensive because the bounded review did not complete itemized PAC-disbursement or lobbying-return review.^{19, 20}

• PayPal’s documented Ukraine-related fundraising and payment-support measures demonstrate corporate activity in another conflict context but do not establish Israel–Palestine-directed financing or logistics.^{1, 2}

• FEC Matter Under Review 7649 concerned PayPal’s termination of a 2020 U.S. presidential campaign’s payment-processing account, and the Commission found no reason to believe that PayPal made a prohibited corporate contribution; the closed matter is unrelated to Israel–Palestine.²⁰

• The PayPal Charitable Giving Fund’s 2024 Form 990 identifies it as operating a donor-advised fund and lists a US$429,496 cash grant to Friends of the Israel Defense Forces, EIN 13-3156445, for “general support.” The return does not identify the underlying donor, donor account, originating partner programme, restriction, or a PayPal Inc. corporate appropriation for the grant.²¹

• The Fund’s 2024 annual report identifies it as a U.S. 501(c)(3) sponsoring organization of donor-advised funds with governance by its own board, including PayPal employees Keala Gaines, Amy Bonitatibus, and Allyson Huve alongside non-PayPal directors.²²

• The annual report states that PayPal provided US$13.4 million of in-kind operational support and waived processing fees across the Fund’s operations in 2024; it does not identify a PayPal Inc. cash contribution to FIDF or to a FIDF-directed donor account.²²

• The reviewed Form 990 and governing documents establish that PayPal Giving Fund had legal control and grant discretion over the US$429,496 FIDF grant. They support characterizing it as a grant from the Fund’s donor-advised-fund operation, but do not establish that PayPal Inc. corporate resources financed it, that PayPal Inc. selected FIDF, or that the underlying donor or recommending account was PayPal Inc.^{21, 6, 16, 17, 23, 22}

• PayPal Giving Fund states that pending donations are held in a non-interest-bearing account, grants are typically unrestricted, and grants remain subject to Fund policies and applicable law; its delivery policy states that grants to enrolled charities are generally distributed monthly through PayPal.^{17, 23}

• A 2024 FIDF grant is verified. Although the 2023 Form 990 was identified, its Schedule I was not retrieved in the reviewed record; a secondary-database report of a 2023 FIDF grant is therefore an unresolved lead rather than a verified recurrence finding. No primary-verified evidence from adjacent-year schedules was retrieved sufficient to confirm recurrence, cessation, or public promotion in another year.^{21, 24}

• Thank Israeli Soldiers’ official donation page states that donors outside the United States or Israel can donate through PayPal. The linked PayPal-hosted page identifies the recipient as Thank Israeli Soldiers and describes its purpose as supporting IDF soldiers during and after service.^{25, 26}

• Thank Israeli Soldiers identifies itself as the trade name of Fund for Israel’s Tomorrow, a U.S. 501(c)(3), EIN 35-2374190; its website and 2025 impact report describe programmes for IDF soldiers and their families.^{27, 26, 28}

• The official Thank Israeli Soldiers page also operates its own Neon CRM donation form. The retrieved PayPal page does not disclose a continuing agreement, approval record, bespoke fee arrangement, approval date, recipient-account enrolment status, duration of availability, compliance review, or PayPal programme-specific discretion beyond operating the hosted payment page.^{27, 25, 26}

• The evidence verifies an active PayPal-hosted Thank Israeli Soldiers donation channel, but no public evidence identified of a continuing formal agreement, bespoke fee arrangement, or PayPal discretion over the charity’s use of donations. The PayPal Giving Fund’s FIDF grant and the Thank Israeli Soldiers payment channel concern different recipient organizations and should not be conflated.^{21, 27, 25, 26, 28}

Corporate Structure & Primary Mission

• PayPal Holdings, Inc. is the SEC registrant whose 2025 Form 10-K is the consolidated annual filing for PayPal and its subsidiaries.¹⁸

• The 2025 Form 10-K states that PayPal, Inc. is a wholly owned subsidiary and identifies foreign subsidiaries including PayPal (Europe) S.à r.l. et Cie, S.C.A. and PayPal U.K. Limited.¹⁸

• PayPal’s significant-subsidiaries exhibit lists entities including PayPal (Europe) S.à r.l. et Cie, S.C.A., PayPal 2 S.à r.l., PayPal Australia Pty Limited, PayPal Canada Co., PayPal do Brasil Instituição de Pagamento Ltda., PayPal Global Holdings, Inc., PayPal International Treasury Centre S.à r.l., PayPal, Inc., PayPal Payment Holdings Pte. Ltd., PayPal Pte. Ltd., and PayPal UK Ltd.²⁹

• The significant-subsidiaries exhibit is limited to significant subsidiaries, so omission from that exhibit does not establish that an entity is outside the PayPal group.²⁹

• PayPal provides Israeli services through the locally licensed entity identified in its Israel legal materials, although the formal ownership chain between PayPal Holdings, Inc. and company number 516478872 was not established in the reviewed materials.^{3, 4, 18, 29}

• BlackRock’s July 2026 Schedule 13G/A reported 71,769,305 PayPal shares, or 8.1% of the class, held by BlackRock reporting business units, and stated that no one person’s interest in PayPal common stock exceeded 5%.³⁰

• No individual controlling shareholder was identified in the reviewed proxy, BlackRock filing, or related SEC materials.^{5, 30}

Executive & Leadership Footprint

• Enrique Lores became PayPal’s President and CEO effective 1 March 2026 after serving as a PayPal director for nearly five years and Board Chair since July 2024.⁵

• David W. Dorman became Board Chair in connection with Lores’s appointment as CEO.⁵

• PayPal’s April 2026 proxy identified eleven director nominees: Joy Chik, Jonathan Christodoro, Carmine Di Sibio, David W. Dorman, Alyssa H. Henry, Enrique Lores, Deborah M. Messemer, David M. Moffett, Ann M. Sarnoff, Deirdre Stanley, and Frank D. Yeary. The proxy states that all nominees other than Lores were independent.⁵

• Alyssa Henry joined the Board in March 2026. The 2025 Form 10-K signature page, filed before her appointment, instead includes Gail J. McGovern among then-directors, explaining the difference between the Form 10-K signature list and April 2026 nominees.^{5, 18}

• The proxy listed Vanguard at 10.05% and BlackRock at 8.06% as of 31 December 2025, while also stating that a later Vanguard Schedule 13G/A reported that Vanguard no longer beneficially owned PayPal shares following an internal reorganization and disaggregation of ownership.⁵

• A report stated that former PayPal CEO and co-founder Peter Thiel attended a September 2025 wedding in Jerusalem, but did not state that he attended meetings with Prime Minister Benjamin Netanyahu or identify a current PayPal role, PayPal investment, or PayPal-directed activity.³¹

• A March 2025 news report stated that PayPal co-founder Max Levchin had expressed support for Israel, but did not identify the underlying statement’s date, forum, or wording. It is therefore an unverified news-report lead rather than independently verified primary evidence of a statement.³²

• No verified primary, non-social-media record was located in the reviewed materials of Israel–Palestine-related donations, family-foundation grants, FIDF/JNF/settlement affiliations, anti-BDS roles, relevant investments, or public advocacy by current Chair David Dorman or the current director nominees. This is not a comprehensive person-by-person absence conclusion because systematic FEC, IRS Form 990/990-PF, state-charity, investment, foundation, and organization-record checks remained incomplete.^{5, 19, 20}