Research cut-off: 20 October 2026.
Entity boundary. This audit concerns current Sandisk Corporation (Nasdaq: SNDK). The present registrant was incorporated in Delaware on 5 February 2024 to hold Western Digital’s Flash Business and had no operations before WDC transferred that business to it.1 The separation became effective at 11:59 p.m. Pacific time on 21 February 2025; regular-way SNDK trading opened on Nasdaq on 24 February 2025.2, 1 Historical SanDisk, M-Systems and Western Digital evidence below is expressly labelled and is used only where it establishes lineage or historical context.
Supply Chain & Sourcing Relationships
Direct supplier relationships. No public evidence identified of current Sandisk procurement from Mehadrin, Hadiklaim, Galilee Export, Agrexco successors, or other Israeli agricultural aggregators/exporters. Sandisk’s present business is flash storage, and its FY2026 filing describes flash-wafer manufacturing through Flash Ventures at Kioxia fabrication facilities in Yokkaichi and Kitakami, Japan.2 Focused searches did not identify a verified Israeli agricultural supplier relationship.
Importer of record structure. Sandisk Israel Ltd. is a current Israeli subsidiary of Sandisk Corporation, but neither the current subsidiary exhibit nor the reviewed entity record identifies it as an importer of record.3, 4 no public evidence identified for a dedicated Israeli importer-of-record subsidiary, joint venture or other verified importer structure.
Seasonal sourcing patterns. No public evidence identified of seasonal procurement from Israeli agricultural suppliers. The reviewed current supply-chain disclosures concern semiconductor/flash production rather than seasonal produce.2
Third-party and indirect sourcing / sales. A possible distributor lead surfaced during research, but the cited category page could not be independently retrieved and its current authorization wording could not be verified. A current authorized Sandisk distribution relationship into Israel is therefore unresolved in this audit. The retrieval gap does not establish that no such relationship exists, and ordinary retailer availability is not treated as proof of an official relationship.
Product Origin, Labeling & Regulatory Compliance
Settlement-origin products. No public evidence identified that Sandisk sells agricultural or other origin-sensitive goods labelled “Produce of Israel,” or that Sandisk products have been cited as settlement-origin goods. The current product disclosures describe flash-storage products and semiconductor manufacturing arrangements.2
Labeling compliance. No public evidence identified of DEFRA, customs or other regulatory enforcement against Sandisk concerning country-of-origin labeling of settlement-produced goods.
Corporate labeling policy. No public evidence identified of a Sandisk corporate policy specifically governing sourcing or labeling of goods from occupied or contested territories.
Authoritative settlement-source check. Searches were run against the named OHCHR/A/HRC, Who Profits, AFSC and DBIO source classes. The DBIO 2025 source describes its annual scope as financial relationships with companies involved in activity sustaining the occupation; the reviewed search did not yield a verified Sandisk-specific DBIO finding.5 This is recorded as “no public evidence identified,” not as proof that no relevant activity could exist. The OHCHR/A/HRC documents surfaced but were not fully retrievable in this session and were therefore not counted as reviewed evidence.
Investment, Capital & Financial Exposure
Current direct investment and R&D footprint. Sandisk’s FY2026 10-K lists owned Flash R&D properties of 204,000 square feet in Kfar Saba and 58,000 square feet in Tefen, plus a leased 39,000-square-foot Flash R&D site in Omer.2 Sandisk’s current office page lists the same three Israeli locations.6 A DNV/IATF certificate dated 28 January 2026 describes Omer as “Engineering” and Tefen/Kfar Saba as “Product Design, Engineering,” corroborating a current engineering/design function.7 The reviewed current disclosures do not identify an Israeli manufacturing function; Sandisk’s wafer-manufacturing disclosure instead places Flash Ventures fabrication in Japan.2
Current Israeli subsidiary. Sandisk’s FY2026 Exhibit 21 lists one Israeli subsidiary, Sandisk Israel Ltd.3 The GLEIF-derived legal-entity record identifies it as an active Israeli limited company, registration number 520038845, created [pre-2020] 9 November 1982, with Western Digital Israel Ltd. as its previous legal name; it records the legal-name change effective 8 April 2025 and Sandisk Corporation as direct and ultimate consolidation parent.4 Patent-assignment records independently show the M-Systems/SanDisk IL/Western Digital Israel/Sandisk Israel name chain through 2025.8
[pre-2020] M-Systems acquisition and lineage. M-Systems’ 2004 filing says it was incorporated in Israel on 10 November 1982, had its principal offices and a manufacturing/R&D facility in Kfar Saba, and leased an R&D facility in Omer.9 SanDisk announced the all-stock acquisition on 30 July 2006 and completed it on 19 November 2006, with M-Systems surviving as a wholly owned SanDisk subsidiary; the closing 8-K valued the consideration at approximately $1.5 billion based on SanDisk’s 17 November 2006 share price.10, 11 This lineage is consistent with the current Sandisk Israel entity’s 1982 creation date.4
[pre-2020] Other historical controlled Israeli entities. SanDisk’s 2007 subsidiary exhibit listed SanDisk IL Ltd. (formerly M-Systems Ltd.), SanDisk Israel (Tefen) Ltd., SanDisk Secure Content Solutions Ltd., U3 Israel Ltd., TwinSys Ltd. (50.1%), TwinSys Data Storage L.P. (50.1%), MR-Flash Ltd. (50.1%), MR-Flash L.P. (50.1%), Smart Caps Ltd. (79.95%), Flash Holdings, Eurom Flashware, Key Computing Ltd. and MegaSIM Ltd. as Israeli group entities.12 The 2004 M-Systems filing had already disclosed Smart Caps at 79.95% and TwinSys/TwinSys Data Storage at 50.1%.9 Later subsidiary exhibits continued to show SanDisk IL and SanDisk Israel (Tefen) under SanDisk in 2013 and Western Digital in 2016; Western Digital’s 2024 exhibit listed Western Digital Israel Ltd.13, 14, 15 Sandisk’s current 2026 exhibit lists only Sandisk Israel Ltd. as an Israeli subsidiary, so no current separate ownership percentage or continuing operation is established for the other historical names.3 For those legacy entities, no current manufacturing site, employee/revenue scale, national/sector market position, or IDF/defence/settlement/critical-infrastructure nexus was verified.
[pre-2020] SanDisk Israel (Tefen) Ltd. status. A current Israeli registry-data aggregator records SanDisk Israel (Tefen) Ltd., company number 512311663, as incorporated 17 April 1996, with last filed annual report in 2018 and legal status “eliminated due to merger.”16 This is a secondary registry-derived source and is treated as corroborative rather than as evidence of a current separate subsidiary.
[pre-2020] MDRM acquisition. SanDisk acquired privately held Israeli company MDRM in a transaction completed 2 December 2004 and renamed it SanDisk Secure Content Solutions.17, 18 Globes reported that official terms were undisclosed and that its sources put the purchase price at $15 million.17 SanDisk’s 2007 subsidiary exhibit listed SanDisk Secure Content Solutions Ltd. as an Israeli subsidiary.12 The current 2026 exhibit does not list that entity separately; no public evidence identified that it remains a current separate Israeli operating subsidiary.3
[pre-2020] Historical tax/incentive and academic links. M-Systems’ 2004 filing described Israeli “Approved Enterprise” tax-benefit programmes and said the Office of the Chief Scientist had committed up to approximately $550,000 to Smart Caps, whose R&D had ceased at the end of 2003.9 A 2024 Meitar case note on Western Digital Israel describes a historical Ramot/Tel Aviv University licensing relationship arising from a Magneton programme project under the Chief Scientist’s Office, and a 2014 $35 million intercompany technology sale.19 no public evidence identified of a current post-separation Sandisk Israel Preferred Technology Enterprise/Special PTE designation or a current 2025-2026 Israel Innovation Authority grant.
Parent and beneficial ownership. Sandisk’s 2026 proxy lists >5% holders Vanguard Capital Management at 7.6%, BlackRock at 6.1%, FMR at 5.4% and Jane Street Group at 5.1%; it lists no holder at or above 10% in that table.20 Western Digital’s May 2026 Schedule 13G/A reported 1,038,681 Sandisk shares, or 0.7%, with no voting power under the post-separation proxy arrangement.21 no public evidence identified of Israeli beneficial control of current Sandisk.
Portfolio, sovereign-finance and insurance exposure. Sandisk is an operating semiconductor/storage company rather than a financial-sector target.2 no public evidence identified in the reviewed current filings of Sandisk underwriting Israeli sovereign debt/Israel Bonds, insuring Israeli state or military operations, holding a disclosed Israel-focused fund, or making disclosed portfolio investments in Israeli sovereign bonds.
Controlling principals. The 2026 proxy identifies David V. Goeckeler as CEO and Chair and lists the current board and principal holders.20 Focused name-by-name searches did not identify verified material personal or family-office investments by a current Sandisk executive, Chair, director or disclosed principal holder into Israeli companies. No current ≥10% shareholder appears in the proxy’s >5% table.20
Operational Presence & Market Activity
Physical footprint. Current Sandisk disclosures identify three Israeli locations: Kfar Saba, Tefen and Omer.2, 6 The 2026 10-K characterizes each as Flash R&D; the DNV certificate characterizes them as engineering/product-design sites.2, 7 No additional current Sandisk facility in the West Bank, East Jerusalem or Golan Heights was identified in the reviewed corporate property and office disclosures.2, 6
Employment and tax/regulatory presence. CTech reported on 24 August 2026 that Sandisk operated three Israeli development centres and employed around 700 people in Israel, with work including chip design, error-correction algorithms and storage systems.22 Sandisk Israel Ltd. is recorded as an active Israeli legal entity.4 No current public figure for Sandisk’s Israel-specific corporate tax paid was identified.
Market positioning and sales. Sandisk’s FY2026 filing reports $20.248 billion of total revenue and groups Europe, Middle East and Africa at $1.732 billion; geography is based primarily on customer ship-to location, and Israel is not separately disclosed.2 The current authorized-distributor lead remains unresolved because its cited document could not be independently retrieved. No Sandisk filing reviewed characterizes Israel separately as a minor market, strategic growth market or regional commercial hub.
Constructive-notice timing. The current Israeli subsidiary and three-site R&D footprint are documented in 2026, after both 19 July 2024 and November 2024.3, 6, 7 no public evidence identified in this Economic research of a current Sandisk settlement-specific or defence-specific activity to which those dates could be tied.
Corporate Structure & Foundational Ties
Founding and incorporation history. The current Sandisk Corporation was incorporated in Delaware on 5 February 2024 for WDC’s Flash Business separation and had no operations before the business transfer.1 It therefore was not founded or incorporated in Israel. Historical M-Systems, by contrast, was incorporated in Israel in 1982 and became a wholly owned SanDisk subsidiary in 2006.9, 11 A 2026 CTech article describes the older SanDisk business as founded in 1988 by Israeli entrepreneur Eli Harari; that is legacy company/brand history, not the incorporation history of the present Delaware registrant.22
Headquarters and domicile. Sandisk Corporation’s principal executive offices are at 951 Sandisk Drive, Milpitas, California, and its legal domicile is Delaware.1 Sandisk maintains Israeli R&D sites but no reviewed filing identifies Israel as a dual or legacy headquarters of the current registrant.2, 6
Israeli-Nexus factor check. Current registrant founded/incorporated in Israel: no; current headquarters/principal management in Israel: no.1 Current Israeli tax residency/PTE status for the parent: no public evidence identified; Sandisk Israel Ltd. is an active Israeli subsidiary, but no current PTE/Special PTE designation was verified.4 Beneficial control by Israeli capital: no public evidence identified, and the current proxy discloses no ≥10% holder.20 Acquired-identity continuity is present historically through M-Systems and MDRM, while the current Israeli subsidiary is Sandisk Israel Ltd.3, 11, 17
State and institutional linkages. No public evidence identified of current Israeli state ownership in Sandisk, Israeli-government board appointees, a verified current Israeli-government contract, or designation of Sandisk as Israeli critical national infrastructure. Historical Chief Scientist/Innovation Authority-linked R&D evidence is described above and is not treated as current.9, 19
Structural governance features. No public evidence identified in the reviewed current proxy, prospectus or filings of an Israeli state golden share, founder share, charter restriction or other governance mechanism tying Sandisk’s corporate mission to the Israeli state.20, 1
Profit Repatriation & Economic Contribution
Revenue attribution. FY2026 net revenue was $20.248 billion; the filing discloses $1.732 billion for Europe, Middle East and Africa but does not separately state Israel revenue.2 No Israel-specific revenue figure was identified.
Profit flows. Sandisk reported $2.879 billion of cash and cash equivalents held outside the United States at 3 July 2026 and said there were no material unaccrued tax consequences for repatriating that cash; the filing does not break this amount out for Israel.2 no public evidence identified that permits a reliable Israel-specific profit-repatriation direction or amount.
Economic ecosystem role. CTech’s August 2026 report describes the Israeli operation as about 700 employees across three development centres focused on core flash technologies.22 Current Sandisk property and certification records corroborate three R&D/design/engineering sites.2, 7 No public government designation or independent sector study reviewed here establishes Sandisk as a national-market-dominant Israeli infrastructure provider.
Footnotes
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https://www.sec.gov/Archives/edgar/data/2023554/000119312526057313/d70029d424b7.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.sec.gov/Archives/edgar/data/2023554/000162828026057406/sndk-20260703.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13 ↩14 ↩15
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https://www.sec.gov/Archives/edgar/data/2023554/000162828026057406/exhibit211-subsidiariesoft.htm ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://www.banktrack.org/event/report_launch_dont_buy_into_occupation_2025 ↩
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https://www.sandisk.com/company/office-locations ↩ ↩2 ↩3 ↩4 ↩5
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https://documents.sandisk.com/content/dam/sandisk/en-us/assets/company/certifications/sdss-iatf-16949-english.pdf ↩ ↩2 ↩3 ↩4
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https://www.sec.gov/Archives/edgar/data/895361/000089536104000028/msystems20f.htm ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/1000180/000095013406014295/f22505exv99w1.htm ↩
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https://www.sec.gov/Archives/edgar/data/1000180/000095013406022131/f25279e8vk.htm ↩ ↩2 ↩3
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https://www.sec.gov/Archives/edgar/data/1000180/000089161807000116/f26836exv21w1.htm ↩ ↩2
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https://www.sec.gov/Archives/edgar/data/1000180/000100018013000009/sndkex-211xsubsidiariesoft.htm ↩
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https://www.sec.gov/Archives/edgar/data/106040/000010604016000033/wdc7116ex21.htm ↩
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https://www.sec.gov/Archives/edgar/data/106040/000010604024000031/wdc-2024q4ex21.htm ↩
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https://webinfo.co.il/details/229325/%D7%A1%D7%A0%D7%93%D7%99%D7%A1%D7%A7-%D7%99%D7%A9%D7%A8%D7%90%D7%9C-%D7%AA%D7%A4%D7%9F-%D7%91%D7%A2-%D7%9E-512311663 ↩
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https://www.eetimes.com/sandisk-acquires-israeli-flash-card-content-provider/ ↩
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https://meitar.com/media/israeli-court-decision-on-ip-valuation-and-transfer-pricing/ ↩ ↩2
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https://www.sec.gov/Archives/edgar/data/2023554/000130817926000423/sndk-20261005.htm ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sec.gov/Archives/edgar/data/106040/000119312526225475/xslSCHEDULE_13G_X02/primary_doc.xml ↩
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https://www.calcalistech.com/ctechnews/article/bjhjpyfdfl ↩ ↩2 ↩3