Key Findings
- Economic: Historical franchise reporting documents former Subway activity in Israel and, in 1997, reported outlets in Al-Bira and a planned Bethlehem outlet; it does not identify those outlets as Israeli settlements, and their duration and current status are unresolved.1
- Military: A contemporaneous 2001 report said the former Israeli chain won an estimated NIS 20 million IDF sandwich tender, but no primary tender, contract, delivery, or payment record was located; performance and continuity are therefore unverified.2
- Political: Reporting describes the later Gur Gal Israeli franchise operation as closing in 2014; no public evidence identified of post-2024 Subway activity in Israel or the occupied Palestinian territory within the bounded review.3
- Not found: No public evidence identified of current Israeli military/security contracts, Israeli surveillance or cybertechnology deployment, settlement operations, or Israel-Palestine lobbying, donations, or state partnerships in the bounded materials reviewed.4, 5, 6, 7, 8, 9, 10
Target Profile
| Field | Detail |
|---|---|
| Company Name | Subway |
| Jurisdiction | United States: Doctor’s Associates LLC (DAL), doing business as Subway, is a Delaware LLC. Subway International B.V. is documented as a Dutch private limited-liability company for an international franchise agreement.11 |
| Headquarters | Shelton, Connecticut, United States, is the business/privacy address documented for DAL and Franchise World Headquarters LLC.11 |
| Sector | Restaurant franchising and consumer food service.12 |
| Ownership | Privately held through acquisition affiliate Underground Purchaser, LLC (UPL), owned by investment funds managed by Roark Capital Management LLC or affiliates. No public Subway beneficial-ownership percentages or complete post-acquisition ownership chart were identified.13, 14 |
| Key Executives / Governance | Jonathan Fitzpatrick, CEO; Damien Harmon, Tracy Gehlan, Joseph Hsu, and Artemio Garza, regional presidents; Ben Selden, CFO; Dennis Leone, Chief Legal Officer; Miguel Piedra, Chief People and Corporate Affairs Officer; Asher Perlmutter, Chief Technology and Commercial Officer. Roark identifies Neal Aronson as founder/managing partner and an Investment Committee member.15, 16, 17 |
| Israeli-Nexus Summary | The record documents historical, franchise-linked Israeli and reported Palestinian-territory activity, plus an unverified 2001 report of an IDF food tender; it does not establish current Israel/occupied-territory operations or a current military, digital, settlement, or political nexus.1, 2, 3, 4 |
Key Facts:
- Subway states that its restaurants are independently owned and operated by franchisees; its system has more than 35,000 restaurants.12
- Roark-affiliate acquisition completion was announced on 30 April 2024.13
- Subway IP LLC and Subway US IP Holder LLC hold documented trademark/proprietary-system roles, while DAL is the U.S. franchisor.11
Executive Summary
Subway is a global restaurant-franchise brand whose restaurants are independently owned and operated by franchisees. Its documented Israel/Palestine nexus is principally historical and franchise-linked, rather than a documented current corporate operating presence. Historical reporting records an Israeli franchise network and a 1997 report of an Al-Bira outlet and a restaurant being established in Bethlehem. The report does not identify those locations as Israeli settlements, does not establish their exact operating periods, and does not document the franchise agreements or ownership records.1
The strongest military-adjacent lead is a January 2001 Ynet report stating that the then-Israeli Subway chain won a tender estimated at NIS 20 million to supply sandwiches to IDF soldiers. The available evidence is contemporaneous press reporting only. It does not identify the tendering authority, supplier legal entity, contract term, performance, deliveries, or payment; no primary procurement or performance record was located. It should therefore be treated as a reported historical tender award, not as verified performance or a continuing IDF relationship.2
The later Israeli franchise activity is reported to have operated in central Israel and closed in 2014. A 2026 retrospective characterises Subway as not having returned to the Israeli market after that closure, but this is press reporting rather than an official closure filing or current official location directory. The audits found no public evidence of post-July or post-November 2024 Subway activity in Israel, the West Bank, East Jerusalem, Gaza, the Golan Heights, or settlements; that conclusion remains bounded by incomplete public corporate, registry, and directory information.3
No public evidence identified of current Israeli defence or security contracts; Israeli-origin surveillance, biometric, cyber, cloud, or military technology deployment; settlement outlet or supply operations; Israel-Palestine lobbying; donations to the IDF, Friends of the IDF, settlement bodies, or related conflict-response organisations; or a corporate public position on Israel/Palestine. Source-scoped checks also found no Subway mention in the reviewed OHCHR settlement-database materials, specified UN/NGO reports, or the BDS Movement’s December 2024 priority guide. These are not proof of universal absence beyond the reviewed sources.4, 5, 6, 7, 8, 9
Under the fixed, human-vetted V6.4 assessment, the documentary record produces a BRS of 0, placing Subway in Tier E (Minimal). The historical and unverified leads are retained in the record, but they do not support a current, verified involvement score.
Timeline of Relevant Events
| Date | Event |
|---|---|
| 1993 | Reporting states Subway entered Israel through an operation described as “Subway Israel,” operated by Yair Tamir.18 |
| March 1997 | Globes reported an Al-Bira restaurant, a restaurant being established in Bethlehem, and prospective locations in Nablus and Bet Hanina. It did not identify an Israeli-settlement outlet.1 |
| January 2001 | Ynet reported that the Israeli Subway chain had won an estimated NIS 20 million tender to supply sandwiches to IDF soldiers. Contract performance remains unverified.2 |
| 2002–2004 | Reporting gives differing closure chronology for the original Israeli operation: an agreement reportedly ended after unpaid royalties in 2002, while other reporting described the chain as closing in 2004.18 |
| 2009 | Globes reported that Gur Gal leased a Herzliya Pituah site and was negotiating a Tel Aviv location; this was reported franchisee activity.19 |
| 26 December 2012 | A Connecticut federal docket records Subway International B.V. v. Gal, a contract matter involving a motion to confirm an arbitration award. The docket does not disclose the award or underlying franchise terms.20 |
| June 2014 | Ynet reported that Gal had opened seven central-Israel branches and that the final outlet had recently closed.21 |
| 30 April 2024 | Subway announced completion of its sale to Roark Capital affiliates; disclosed financing records place acquisition completion at the 30 April/1 May boundary.13 |
| 28 July 2025 | Jonathan Fitzpatrick became Subway CEO.15 |
| 2026 | A Ynet retrospective reported that the Israeli activity closed in 2014 and that Subway did not return to the Israeli market; this remains press reporting rather than a corporate registry or closure filing.3 |
Corporate Overview
DAL is the U.S. Subway franchisor and a Delaware LLC. Subway’s disclosed structure includes UPL, Subway Worldwide System Holdings LLC, Subway US Holdings LLC, Subway Funding Holdco LLC, Subway Funding LLC, Subway US IP Holder LLC, Subway IP LLC, FWH Technologies LLC, Franchise World Headquarters LLC, and other service, advertising, payment, real-estate, and franchise entities. The disclosed records identify a detailed U.S. acquisition and financing chain, but do not provide a complete consolidated group chart or resolve every direct-parent relationship after the 2024 securitisation.11, 13, 14
UPL acquired the relevant Subway parent equity interests through transactions backed by Roark-managed investment funds. Subway’s public materials identify the brand as privately held; no issuer-level SEC reporting, complete Subway board roster, UPL manager roster, or public beneficial-ownership percentages were identified in the reviewed materials.13, 14
The international franchise relationship is not equivalent to direct corporate operation. Subway states that restaurants are independently owned and operated by franchisees. Subway International B.V. is documented as an international franchising entity, but available franchise materials do not establish a current Israeli subsidiary, Israeli franchisee legal entity, Israeli corporate office, or current Israel/occupied-territory location operated by DAL, Subway International B.V., or the named U.S. entities.11, 12
Historically, reporting identifies Israeli franchise operations under Yair Tamir and later Gur Gal. The record also includes reported activity in Palestinian localities in the 1990s. Neither the historical reporting nor the docket evidence establishes a current franchise right, current outlet, or current operating relationship in Israel or the occupied Palestinian territory.1, 3, 18, 20
Domain Summaries
Military: Military
Mechanism of Involvement
The sole identified Israel-specific military-adjacent lead is the 2001 Ynet report of a then-Israeli Subway-chain tender to supply sandwiches to IDF soldiers, estimated at NIS 20 million. If performed, this would concern prepared food for soldiers rather than weapons, dual-use production, defence-industrial integration, strategic logistics, or military infrastructure.2
No public evidence identified of current contracts, tenders, framework agreements, or memoranda involving Subway, DAL, Subway IP LLC, UPL, Roark, or disclosed affiliates and the IDF, Israeli Ministry of Defence, Israel Prison Service, or Border Police. No public evidence identified of defence-prime supply relationships, military-specific products, export-control activity, construction or engineering connected to military infrastructure, or weapons-system involvement in the bounded materials reviewed.4, 10
Subway also operates food-service franchise locations at some U.S. military-exchange facilities. Those domestic U.S. concession arrangements are unrelated to Israeli defence logistics and do not establish an Israeli military nexus.22
Counter-Arguments and Evidence Limits
The company’s strongest defence is its civilian food-service character and the absence of a verified current Israeli defence relationship. The 2001 item is a press report, not a procurement instrument: no tender notice, award document, supplier registration, invoice, delivery confirmation, payment record, term, or end date was located. The evidence does not independently establish performance, scope, geographic delivery, or continuation.2
The reviewed IMOD portals did not display Subway-related entries, but this is a rendered-portal observation and does not prove that complete historical procurement records contain none. Likewise, the absence findings are bounded by the materials reviewed rather than proof of absence in all possible records.4
Named Entities and Evidence Map
- Israeli Subway chain / unidentified supplier entity: reported recipient of the 2001 tender; legal identity and performance unresolved.2
- IDF: reported end-user in the 2001 article; no primary procurement record located.2
- DAL, Subway IP LLC, UPL, Roark: no public evidence identified of current Israeli defence contracts in the reviewed record.4
Digital: Digital
Mechanism of Involvement
Subway’s documented technology relates to restaurant operations and consumer engagement: point-of-sale systems, digital ordering, loyalty communications, personalisation, analytics, and customer-experience research. Its North American loyalty programme has used Adobe Journey Optimizer, Adobe Campaign, and Adobe Target; Subway has also used UserTesting and Merkle for customer-experience and data/technology work.23, 24, 25
Subway collects and processes consumer and franchise-related information and states that personal information may be transferred to and processed in the United States and other countries. Public privacy materials do not identify a cloud provider, Israeli data centre, Israel-specific processing arrangement, Israeli subprocessor, or Israeli state customer.26, 27
No public evidence identified of Subway licensing, deploying, or using named Israeli-origin enterprise, cyber, surveillance, biometric, predictive-policing, or military technologies. No public evidence identified of participation in Project Nimbus, Israeli government cloud, or provision of AI, autonomous, surveillance, or digital systems to Israeli military, intelligence, or law-enforcement bodies in the bounded materials reviewed.4, 5, 10
Counter-Arguments and Evidence Limits
The strongest defence is that the disclosed stack is ordinary retail and marketing technology, not state-security technology. The record identifies selected vendors but not Subway’s full cloud, hosting, cybersecurity, subprocessor, or franchisee-level technology inventory. The non-findings therefore do not prove that no individual franchisee has ever used an Israeli-origin product; they establish that no such relationship was publicly identified in the reviewed sources.23, 26, 24, 25
Named Entities and Evidence Map
- DAL / Franchise World Headquarters / FWH Technologies / Subway US IP Holder: documented Subway operating, service, IP, and SubwayPOS roles.11, 26
- Adobe, UserTesting, Merkle: documented customer-experience and marketing/technology suppliers; no Israeli state-security nexus identified.23, 24, 25
- Named Israeli-origin technology vendors: no public Subway deployment relationship identified in the bounded audit record.4, 5
Economic: Economic
Mechanism of Involvement
The economic record consists primarily of historical franchise-linked operations. The 1997 report records an Al-Bira restaurant and a restaurant being established in Bethlehem, with higher reported haulage costs to the “Territories.” It does not establish product origin, a Subway corporate distribution entity, or settlement activity.1
Historical reporting also documents former Israeli franchising. The later Gur Gal operation reportedly opened seven central-Israel locations and closed in 2014. A 2026 retrospective says Subway did not return thereafter, but this is not an official closure notice or registry record.3, 21
Subway’s franchise model separates franchisee operations from centrally owned assets: franchisees pay royalties and advertising fees, while purchasing arrangements are organised through regional co-ops. No public evidence identified of a current Israeli purchasing co-op, Israeli supplier, importer, warehouse, distributor, Israeli operating-company acquisition, Israeli R&D/manufacturing/data-centre investment, Israel Bonds exposure, or quantified current Israel-attributable revenue, royalties, tax, payroll, or profit repatriation.12, 28
Counter-Arguments and Evidence Limits
The strongest defence is that the historical locations were franchisee activity, not evidence of a current Subway-owned Israeli asset or present economic contribution. The 1997 locations were not described as settlements, and their continuing status is unknown. The available record lacks a current official Israeli directory, registry extract, complete ownership chart, and franchisee-level sourcing records; hence the conclusion is a bounded no-current-evidence finding, not categorical proof that no rights or activity exist.1, 3, 28
Reported Israeli outlets were divested/closed historical operations rather than verified current operations. Under the dossier’s temporal approach, exited or discontinued operations materially mitigate present involvement.3, 21
Named Entities and Evidence Map
- Yair Tamir / “Subway Israel”: reported historical Israeli operator; dates and peak outlet count vary between reports.18
- Adnan Bahur: named in 1997 reporting as a West Bank franchisee associated with the Al-Bira outlet.1
- Gur Gal: reported later Israeli franchisee; litigation docket confirms an arbitration-related contractual dispute but not franchise terms or current rights.19, 20
- IPC / IPCEMEA: documented purchasing structures in other franchise contexts; neither cited material identifies an Israeli purchasing arrangement.28
Political: Political
Mechanism of Involvement
No public evidence identified of a Subway corporate statement on Israel-Palestine, a settlement policy, political-speech enforcement, anti-BDS lobbying, relevant corporate-PAC activity, corporate donations to the IDF, Friends of the IDF, JNF/KKL, settlement bodies, or Israeli state-aligned conflict-response organisations in the bounded materials reviewed.4, 5, 6, 7, 8
No public evidence identified of Israeli state ownership, golden shares, Israeli government partnership, settlement sponsorship, reservist-support programme, military-welfare support, or conflict-period resource mobilisation in the bounded materials reviewed. The reviewed BDS priority guide does not name Subway; this is a guide-specific finding and does not exclude other advocacy elsewhere.4, 5
A 2018 American Jewish Committee sponsor roster lists “Wendy & Neal Aronson” as “Advocates.” The roster does not identify a donation amount, establish that the person listed is Roark’s Neal Aronson, or evidence support for the Israeli state, military, settlement organisations, or anti-BDS campaigning. It is therefore not a substantiated corporate political nexus.29
Counter-Arguments and Evidence Limits
The strongest defence is the lack of documented corporate political conduct connecting Subway to Israel/Palestine. Subway’s franchised and decentralised operating model also means franchisee activity should not automatically be attributed to DAL, UPL, Roark, or the brand without evidence of control, direction, or corporate participation.12
The relevant no-hit results are source-scoped. The reviewed UN, OHCHR, NGO, AFSC, Who Profits, and BDS materials do not establish universal absence from every report, proceeding, campaign, or database. No public evidence identified of an accessible court, OECD, regulatory, or UN proceeding naming Subway in connection with settlement activity or the conflict in the bounded searches.4, 5, 6, 7, 8, 9
Named Entities and Evidence Map
- Subway / DAL / UPL / Roark: no public evidence identified of relevant corporate political donations, lobbying, or state partnership in the bounded materials reviewed.4, 16, 5
- Neal Aronson: Roark founder and managing partner; the cited AJC roster is insufficient to attribute a relevant donation or political position.15, 29, 16
- BDS Movement and reviewed UN/NGO materials: no Subway-specific finding in the specified materials; document-scoped only.4, 5, 6, 7, 8, 9
BDS-1000 Score
Method: V6.4 fixed-three evidence panels with deterministic target-nexus replay.
| Domain | I | M | P | V-Domain Score |
|---|---|---|---|---|
| Military | 5.50 | 0.00 | 7.50 | 0.00 |
| Digital | 0.00 | 0.00 | 0.00 | 0.00 |
| Economic | 3.50 | 0.00 | 7.50 | 0.00 |
| Political | 3.50 | 0.00 | 8.00 | 0.00 |
- V_MAX: 0.00 Avg_OTHERS: 0.00
- BRS Score: 0 Tier: E (Minimal)
The historical leads affect the recorded Impact and Proximity fields, but the human-vetted Magnitude values are zero because the available evidence does not verify a current, material, continuing nexus. V_MAX is therefore 0.00, producing Tier E (Minimal). The V6.4 method is evidence-only and uses fixed-three evidence panels with deterministic target-nexus replay, subject to vetting and temporal/entity-attribution limits.
Methodology Note
- Evidence is limited to the four supplied domain audits and their cited sources; no claim is inferred from corporate affiliation alone.
- Impact (I) reflects activity type; Magnitude (M) reflects documented scale; Proximity (P) reflects directness to the relevant conduct.
- The assessment is scale-free and evidence-only; a lead that lacks a verified contract, performance record, current activity, or attributable legal entity is not hardened into a confirmed nexus.
- Divested, closed, or exited operations are temporally mitigated and are not treated as equivalent to current operations.
- Entity attribution is not transitive: franchisee, investor, executive, affiliate, and parent-level facts require evidence tying the relevant entity to the conduct.
- Settlement operations, if documented, may be considered in both economic and political domains; no public evidence identified of such Subway operations in the bounded record.
- “No public evidence identified” means that the specified checks found no evidence; it does not establish universal absence outside the reviewed record.
Footnotes
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https://en.globes.co.il/en/article-370832 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://www.ynet.co.il/articles/0%2C7340%2CL-473549%2C00.html ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://www.ynet.co.il/economy/article/s1bpp00u1fx ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://docs.un.org/en/A/HRC/59/23 ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13
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https://bdsmovement.net/Guide-to-BDS-Boycott ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9
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https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session31/database-hrc3136/23-06-30-Update-israeli-settlement-opt-database-hrc3136.pdf ↩ ↩2 ↩3 ↩4 ↩5
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https://www.ohchr.org/en/press-releases/2025/09/un-human-rights-office-updates-database-businesses-involved-israeli ↩ ↩2 ↩3 ↩4 ↩5
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https://investigate.afsc.org/all-companies?page=0 ↩ ↩2 ↩3 ↩4 ↩5
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https://www.sibat.mod.gov.il/Industries/directory/Pages/default.aspx ↩ ↩2 ↩3
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https://apps.dfi.wi.gov/apps/FranchiseSearch/details.aspx?hash=1703189294&id=641453&search=external&type=GENERAL ↩ ↩2 ↩3 ↩4 ↩5 ↩6
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https://newsroom.subway.com/2024-04-30-Subway-R-Sale-to-Roark-is-Complete ↩ ↩2 ↩3 ↩4 ↩5
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https://storage.googleapis.com/franchiseindx_fdds/Food-Beverage/Subway_2025_WwzFoj6P ↩ ↩2 ↩3
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https://newsroom.subway.com/2025-08-18-Subway-Names-New-Regional-Presidents-to-Lead-Brands-Next-Chapter ↩
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https://www.ynet.co.il/articles/0%2C7340%2CL-4528874%2C00.html ↩ ↩2 ↩3 ↩4
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https://dockets.justia.com/docket/connecticut/ctdce/3%3A2012cv01803/99311 ↩ ↩2 ↩3
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https://www.ynet.co.il/articles/0%2C7340%2CL-4528874%2C00.html ↩ ↩2 ↩3
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https://business.adobe.com/uk/customer-success-stories/subway.html ↩ ↩2 ↩3
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https://www.usertesting.com/resources/customers/subway ↩ ↩2 ↩3
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https://www.merkle.com/en/work/case-studies/subway.html ↩ ↩2 ↩3
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https://www.ajc.org/sites/default/files/pdf/2018-04/AJC-Global-Forum-Sponsors.pdf ↩ ↩2






