Military Audit: Surfshark

Direct Defence Contracting & Procurement

No public evidence identified of Surfshark, Surfshark B.V., or Nord Security holding an Israeli Ministry of Defense, Israel Defense Forces, Israel Prison Service, Border Police, or other Israeli security-body contract, tender award, framework agreement, or official cooperation announcement.

Surfshark’s published terms identify Surfshark B.V. as the customer contracting entity, established in the Netherlands at Kabelweg 57, 1014BA Amsterdam, while stating that contracts remain governed by British Virgin Islands law ¹.

The reviewed corporate materials describe Surfshark as a consumer cybersecurity and privacy business and do not describe a defence business unit or military customer programme ²³.

No public evidence identified of Surfshark appearing in reviewed Israeli defence-export directories, defence-exhibition catalogues, or procurement registries in connection with Israeli state contracts.

Dual-Use Products & Tactical Variants

Surfshark describes its public product portfolio as VPN, antivirus, breach-alert, private-search, alternative-identity and phone-number, data-deletion, and employee-protection services ²⁴.

Surfshark’s Code of Conduct likewise concerns the company’s general business standards and does not describe tactical, ruggedised, military-specific, kinetic-targeting, fire-control, or weapons-integration products ⁴.

Surfshark markets eight Israeli VPN servers and identifies Tel Aviv as the connection location for that consumer service ⁵.

The Israel-server page does not name an Israeli government or military end user, state a contract modification, provide end-user certification information, or establish the physical hosting location, operator, data-centre provider, or reseller ⁵.

No public evidence identified of Israeli military or security export licences, end-user certificates, or export-control decisions concerning Surfshark products.

Heavy Machinery, Construction & Infrastructure

No public evidence identified of Surfshark equipment or services being used for construction, demolition, settlement infrastructure, checkpoints, detention facilities, the separation barrier, or military installations in occupied territory.

Surfshark’s corporate page lists offices in the Netherlands, Lithuania, Poland, and Germany and does not list an office in Israel, the West Bank, East Jerusalem, or the Golan Heights ².

This company office list is not a complete operational-footprint disclosure and therefore does not establish the absence of Israeli operations or infrastructure ².

No public evidence identified of Surfshark dealers, franchisees, or authorised resellers operating in West Bank, East Jerusalem, or Golan Heights settlements.

Supply Chain Integration with Defence Primes

Surfshark states that it merged with Nord Security under one holding company in 2022 while continuing to operate independently ².

Surfshark’s merger announcement states that the companies would retain separate infrastructure, management, and product-development plans ⁶.

Nord Security’s April 2022 announcement describes Surfshark’s portfolio as consumer VPN, antivirus, breach detection, private search, and data-deletion tools ³.

Nord Security identified Tom Okman and Eimantas Sabaliauskas as its co-founders and identified Novator Ventures, Burda Principal Investments, and General Catalyst among the financing participants, without disclosing current ownership percentages or voting control ³.

No public evidence identified of Surfshark or its Nord Security group supplying Elbit Systems, Israel Aerospace Industries, Rafael, IMI/Elbit Land, or another Israeli defence prime with components, specialist services, joint development, co-production, or licensed technology.

Logistical Sustainment & Base Services

No public evidence identified of Surfshark providing telecommunications, facilities, transport, catering, waste, fuel, freight, shipping, port, or base-support services to Israeli military or security installations.

No public evidence identified of Surfshark providing such services to installations in the West Bank, East Jerusalem, Golan Heights, or Negev.

Surfshark’s recruitment privacy notice identifies Surfshark B.V. in the Netherlands, netflow, UAB in Lithuania, Radically Better Internet Poland Sp. z o.o. in Poland, and 360Civic Inc. doing business as Ironwall in the United States within its recruitment context ⁷.

That notice does not provide ownership percentages, incorporation numbers, or a formal group chart for those entities ⁷.

Munitions, Weapons Systems & Strategic Platforms

No public evidence identified that Surfshark or Surfshark B.V. manufactures, integrates, maintains, or supplies weapons, munitions, precursor materials, kinetic AI, missile-defence components, guidance or fire-control systems, armoured-vehicle systems, or strategic military platforms.

An independent reasonable-assurance report dated 10 June 2025 identifies Surfshark B.V. as the entity engaging the reviewer for assurance over IT systems and operations supporting its customer VPN service ⁸.

The assurance report does not describe military or weapons-system work ⁸.

Surfshark’s 2025 annual wrap-up identifies Vytautas Kaziukonis as CEO, whereas its current corporate page lists Dovydas Godelis as CEO and Kaziukonis as Chair of the Board ²⁹.

The reviewed sources do not state the effective date or legal documentation for that apparent leadership transition ²⁹¹⁰.

Export Licensing, Regulatory & Legal History

No public evidence identified of an export-licence grant, denial, suspension, revocation, enforcement action, sanctions investigation, OECD National Contact Point complaint, or court proceeding concerning a Surfshark defence-supply relationship with Israel.

No public evidence identified of a verified military or security relationship whose continuation could be assessed after 19 July 2024 or November 2024.

Bloomberg LEI identifies Surfshark B.V. as a Dutch private limited company with KVK registration number 81967985, created on 22 February 2021 ¹¹.

The LEI record does not identify a direct parent because no parent LEI is recorded, which is not evidence that Surfshark lacks a parent or controller ¹¹.

No public ownership cap table, shareholder register, beneficial-ownership filing, or formal legal group chart was located in the reviewed corporate and LEI materials ⁷¹¹³.

Civil Society Scrutiny & Documented Investigations

The supplied document-scoped pre-scan reported no mention of Surfshark in the 2025 UN Special Rapporteur report From economy of occupation to economy of genocide ¹².

The supplied document-scoped pre-scan also reported no mention of Surfshark in the 2023 OHCHR update of its database of business enterprises involved in certain settlement-related activities ¹³.

The absence of an exact hit in those identified documents does not establish database-wide, sector-wide, or all-source absence ¹²¹³.

No public evidence identified of a documented boycott or divestment campaign, institutional exclusion decision, parliamentary inquiry, or company response specifically grounded in Surfshark’s alleged Israeli defence-sector activities.

The reviewed materials do not identify an Israeli subsidiary, franchisee, licensee, authorised reseller, military customer, or occupied-territory location, although the bounded review cannot establish their non-existence ¹⁷²¹¹.