Vanguard

Key Findings

• Economic: Vanguard’s documented nexus centres on managed securities exposure: a fund reported $11.049 million in two State of Israel bonds at 30 September 2025; separate Vanguard Capital Management and Vanguard Fiduciary Trust Company filings reported Elbit Systems positions at 30 June 2026. The latter positions cannot automatically be treated as a consolidated beneficial-ownership total.^{1, 2, 3}
• Digital: Vanguard Capital Management and Vanguard Portfolio Management separately disclosed substantial Palantir positions at 30 June 2026. These establish investment exposure; they do not establish Vanguard’s provision of Palantir software to Israeli institutions.^{2, 4}
• Political: Business & Human Rights Resource Centre recorded Vanguard’s non-response to a July 2024 inquiry concerning UN experts’ arms-transfer concerns. Any subsequent response remains unverified; the record does not establish endorsement of Israeli policy.⁵
• Not found: No public evidence identified of direct Vanguard weapons supply, Israeli military technology contracts, or Vanguard-operated settlement facilities. Portfolio-company activities are not established as Vanguard’s own operations.^{6, 7, 8, 9}

Target Profile

Executive Summary

Vanguard’s documented Israel/Palestine nexus is principally financial. Its investor-owned management structure serves funds and clients whose portfolios include sovereign and corporate securities. A Vanguard portfolio report directly identifies two State of Israel bonds worth a combined $11.049 million at 30 September 2025. SEC information tables also document Elbit Systems holdings reported separately by Vanguard Capital Management LLC and Vanguard Fiduciary Trust Company at 30 June 2026. These records establish securities exposure, while leaving important questions about acquisition channels, underlying beneficial ownership and subsequent holdings unresolved.^{10, 1, 2, 3}

The strongest contemporary primary evidence concerns the named reporting managers. Vanguard Capital Management reported 759,204 Elbit shares worth approximately $577.3 million; Vanguard Fiduciary Trust Company separately reported 243,554 shares worth approximately $185.2 million. Their voting-authority disclosures differ: the former reported no voting authority over its position, while the latter reported sole voting authority. A January 2026 reorganisation changed investment-management responsibilities, limiting comparisons with earlier Vanguard Group disclosures. Neither a decline across different reporting entities nor an arithmetic aggregation establishes a verified disposal or consolidated beneficial-ownership total.^{14, 2, 3}

Technology-related exposure likewise concerns securities rather than demonstrated technology provision. Vanguard Capital Management and Vanguard Portfolio Management separately reported large Palantir positions in June 2026. Vanguard’s confirmed enterprise technology relationships concern its own financial-services operations, including Infosys and AWS. No public evidence identified of Vanguard supplying targeting software, surveillance systems, military cloud services or other digital capabilities to Israeli security institutions. The existence of a portfolio holding or a shared technology supplier does not establish such a contract.^{2, 4, 8, 9}

Political scrutiny includes an official OHCHR communication concerning investors and arms transfers, and Business & Human Rights Resource Centre’s documented July 2024 non-response record. These are evidence of concerns raised and correspondence outcomes, not judicial findings or proof of political endorsement. No public evidence identified of a specific Israel-related Vanguard lobbying action, qualifying corporate military-welfare donation, or direct settlement operation in the examined records.^{5, 7, 15}

The fixed, human-vetted V6.6 assessment is BRS 108, Tier E (Minimal/No Complicity). Economic exposure produces the only non-zero domain score, Economic 1.29. Military and digital investment relationships remain documented in the narrative without being converted into direct supply relationships; the political record retains its limited, dated character.

Timeline of Relevant Events

Corporate Overview

Vanguard provides investment management, advice and retirement services. Its corporate disclosures report more than 50 million investors, approximately 20,000 employees and 487 funds worldwide as of the respective reporting dates. These global figures describe organisational scale; they do not quantify Israel-specific operations or economic contribution.²³

The management company is owned by its US-domiciled member funds, ultimately owned by fund investors. Managed securities should therefore be distinguished from the management company’s corporate capital and from acquisitions of controlled operating businesses. No individually named shareholder with a controlling corporate stake was established through the reviewed ownership disclosures.^{10, 24}

The January 2026 restructuring established wholly owned Vanguard Capital Management LLC and Vanguard Portfolio Management LLC and delegated investment-management responsibilities while retaining the affected funds’ objectives and strategies. Vanguard Fiduciary Trust Company appears separately in the audited investment-reporting record. Vanguard Marketing Corporation performs brokerage-related functions, while Vanguard Advisers and other named affiliates undertake investment-management or associated services.^{14, 3, 25}

No public evidence identified of a Vanguard-owned Israeli branch, operating headquarters, engineering centre, settlement facility or controlling acquisition of an Israeli operating company. No Israeli franchise relationship was established. The documented nexus is investment exposure, without a separately verified Israeli operating footprint.^{11, 14, 24}

Domain Summaries

Military: Military

Mechanism of Involvement

The military audit documents financial relationships with defence-sector issuers. The 2025 UN Special Rapporteur’s report recorded Vanguard positions of approximately 2.0% in Elbit Systems and 9.2% in Lockheed Martin as of 13 May 2025. Those dated figures were not independently verified as current ownership percentages at the October 2026 cutoff.⁶

More recent SEC evidence confirms a Vanguard Capital Management Elbit position of 759,204 ordinary shares worth $577,278,982 at 30 June 2026. Compared with the same manager’s March disclosure, the share count increased by 45,433, approximately 6.37%, while reported market value declined by approximately 4.07%. These observations do not establish acquisition dates, prices, counterparties or whether the movement resulted entirely from open-market purchases.^{2, 22}

Elbit’s ammunition agreement with Israel’s Ministry of Defence provides a documented investee procurement relationship. Vanguard’s holdings and Elbit’s contract are separate records: neither establishes Vanguard as manufacturer, subcontractor, purchaser or supplier under that agreement.^{6, 17}

Counter-Arguments and Evidence Limits

Vanguard’s strongest defence is the distinction between managing investments and performing military contracts. No public evidence identified of direct Vanguard defence procurement agreements, weapons manufacturing, military component supply, export licensing, base services or weapons-development partnerships with Israeli security bodies. The audited evidence does not establish operational control over portfolio-company military activities.^{6, 17, 24}

Vanguard Capital Management’s June Elbit table reports zero sole voting authority, zero shared voting authority and all 759,204 shares under “none.” That limits claims about this manager’s disclosed voting authority; it cannot be generalised to every Vanguard entity, because Vanguard Fiduciary Trust Company separately reported sole authority over its Elbit position.^{2, 3}

The UN report’s approximately $546 million treasury-bond purchase figure does not identify an earmarked payment to a particular military unit or weapons programme. Its findings represent published international scrutiny, not a judicial determination of Vanguard’s liability. No verified Vanguard corporate FIDF donation was established in the audits.^{6, 7, 15}

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

The strongest digital-sector evidence is investment exposure to Palantir. Vanguard Group beneficial-ownership disclosures reported 10.15% at 31 December 2024 and 8.82% at 31 March 2025. Subsequent reporting must be read alongside the 2026 reorganisation rather than treated as an uninterrupted series for an unchanged reporting manager.^{14, 18, 19}

At 30 June 2026, Vanguard Capital Management reported 146,137,514 Palantir Class A shares worth $17,049,863,758. Vanguard Portfolio Management separately reported 50,276,809 shares worth $5,865,795,306. Both tables reported zero sole and shared voting authority and placed the full positions under “none.” Their arithmetic sum is 196,414,323 shares worth $22,915,659,064, subject to unresolved overlap in beneficial ownership or reporting arrangements.^{2, 4}

Vanguard Capital Management’s amended March table reported 144,837,529 Palantir shares. Its June share count was approximately 0.90% higher, while reported value declined approximately 19.5%. These quarter-end changes do not identify the underlying purchases, disposals, transfers or other transactions.^{2, 26}

Counter-Arguments and Evidence Limits

The filings establish securities relationships, without establishing a Vanguard contract to purchase Palantir software or distribute it to Israeli government customers. No public evidence identified of direct Vanguard Israeli military or intelligence technology contracts, offensive cyber provision, autonomous targeting systems, settlement surveillance services or Project Nimbus participation.^{2, 4, 7, 9}

Vanguard’s confirmed Infosys partnership concerns retirement-plan recordkeeping; the AWS evidence concerns its internal cloud-service governance. Neither establishes Israeli military involvement. No public evidence identified of a specifically named Israeli-origin surveillance platform deployed through these arrangements or customer data routed through Israeli-controlled infrastructure. The reviewed disclosures do not provide a complete infrastructure or processing-jurisdiction inventory.^{8, 9, 27}

Vanguard’s stewardship report explains separate 2026 responsibilities. Consequently, neither entity’s reported Palantir position should automatically be treated as the other’s holdings or voting rights. The fixed Digital 0.00 preserves the distinction between documented investment exposure and an unestablished direct digital-service mechanism.²⁸

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

Economic involvement rests on identifiable sovereign and corporate securities. Vanguard’s September 2025 portfolio report lists a State of Israel bond with a 5.000% coupon, maturing 30 October 2026, valued at $9.791 million, and another with a 1.500% coupon, maturing 18 January 2027, valued at $1.258 million. Their combined reported market value was $11.049 million. The acquisition dates, counterparties and primary-versus-secondary purchase status were not established; maturity dates do not prove continued ownership.¹

The Elbit record includes a secondary-source December 2025 observation of 998,267 shares attributed to Vanguard Group. June 2026 primary filings separately show 759,204 shares for Vanguard Capital Management and 243,554 for Vanguard Fiduciary Trust Company. Their arithmetic sum is 1,002,758 shares worth $762,471,111. This is a sum of reported manager positions, not a verified consolidated beneficial-ownership total.^{21, 2, 3}

A secondary N-PORT compilation reports approximately $416.2 million in Israeli government and government-related bonds for Vanguard Total Bond Market Index Fund at 30 June 2026, and approximately $572.9 million for Vanguard Total International Bond Index Fund at 31 July 2026. The complete security-level schedules were not independently reconciled in the audit. These aggregates therefore remain secondary-source findings; related fund-series figures must not be automatically combined.^{29, 30}

Counter-Arguments and Evidence Limits

The strongest defence concerns ownership, financial-flow attribution and reporting changes. Assets under management belong to investors. Securities market values are not Vanguard operating revenue, profit, fees, tax payments or direct corporate expenditure. Holdings do not by themselves establish new capital supplied directly to the issuer, and the audited records do not quantify aggregate primary-market financing or the eventual expenditure of proceeds.^{10, 1, 24}

The January reorganisation prevents interpreting the difference between Vanguard Group’s December Elbit position and Vanguard Capital Management’s June position as a verified sale. Conversely, adding Capital Management and Fiduciary Trust figures does not conclusively establish distinct ultimate beneficial interests. Different valuation dates also limit market-value comparisons.^{21, 14, 2, 3}

No public evidence identified of Vanguard acting as Israeli sovereign lead underwriter, bookrunner or authorised Israel Bonds distributor; directly lending to defence or settlement businesses; or controlling an Israeli operating acquisition. No Vanguard-specific settlement-business finding was independently established from the examined database material. Total current Israeli equity exposure and net economic contribution remain unquantified.^{1, 14, 24, 31}

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

The clearest political record concerns external scrutiny and response status. OHCHR communication OTH 101/2024 named Vanguard among investors associated with allegations concerning defence companies transferring weapons to Israel. The communication records concerns raised through UN Special Procedures, rather than a judicial finding.⁷

Business & Human Rights Resource Centre invited Vanguard to respond on 3 July 2024 and published a non-response record dated 12 July. Its 24 July follow-up discussed responses across the contacted companies and investors. A later Vanguard response or formal withdrawal of its non-response record was not independently established.^{5, 32}

Vanguard’s public-policy disclosures describe financial-market advocacy and the Vanguard Committee for Responsible Government, a PAC funded through voluntary contributions from eligible officers. No specific Israel-, settlement-, BDS- or military-assistance-related contribution or lobbying action was independently verified.¹⁵

Counter-Arguments and Evidence Limits

A dated non-response does not establish endorsement of Israeli policy, military operations or every position associated with broader divestment campaigns. The audits did not verify a sufficiently complete comparative communications record to support claims of selective silence across different crises.^{5, 15, 32}

Vanguard states that stewardship serves long-term investment returns and does not pursue public-policy objectives. Its Investor Choice programme permits eligible investors to select voting policies for their proportionate participating holdings. No individual Israel/Palestine shareholder proposal was independently matched to a specific Vanguard vote or suppression attempt.^{33, 34, 35}

No public evidence identified of qualifying corporate or named-principal donations to Israeli military-welfare or settlement organisations, direct settlement operations, or a verified Palestine-specific employee discipline or content-suppression programme. Searches of leadership disclosures do not establish the absence of undisclosed private interests. The fixed political assessment retains I=2.00, with M=0.00, P=0.00 and Political=0.00; the limited record is not elevated into established political support.^{7, 12, 15, 36}

Named Entities and Evidence Map

Complicity Index Score

Method: V6.6. Final human-vetted values; fixed as supplied.

• V_MAX: 1.29 Avg_OTHERS: 0.00
• BRS Score: 108 Tier: E (Minimal/No Complicity)

Documented sovereign-debt and corporate-equity exposure supplies the economic mechanism behind V_MAX 1.29, with substantial reported positions qualified by indirectness, fund ownership and unresolved financing channels.^{10, 1, 2, 3} The absence of established direct military or digital provision, together with the limited political record, is consistent with the supplied Tier E outcome.^{5, 7, 8, 9} This scale-free, evidence-only, vetted assessment preserves the supplied values without inferring a numerical rationale beyond the audited facts.

Methodology Note

• This dossier synthesises only the four supplied domain audits, with a research cutoff of 28 October 2026. It retains distinctions between primary disclosures, secondary compilations, corporate statements and allegations.
• The scale-free framework treats Impact (I) as activity type, Magnitude (M) as scale and Proximity (P) as directness. The supplied V6.6 scores are fixed; global corporate size does not independently establish a qualifying nexus.
• Temporal attribution uses dated observations. Verified divestments or exits mitigate historical involvement; an unknown later status is neither continued ownership nor an exit. The 2026 reporting reorganisation prevents unsupported disposal inferences.¹⁴
• Entity attribution excludes transitive guilt: an investee’s contract or a supplier’s unrelated activity is not automatically Vanguard’s act. Separate manager positions are not automatically consolidated beneficial ownership.^{2, 3, 4}
• Verified settlement operations dual-count under Economic and Political where applicable. Here, no public evidence identified of a direct Vanguard settlement operation; that mechanism is not presumed from portfolio exposure.^{7, 31}
• “No public evidence identified” denotes the outcome of the reviewed checks, not proof of universal absence. Unverified continuation, incomplete primary reconciliation and unresolved ownership overlap remain explicit.