Wise - Digital Audit

Enterprise Technology Stack & Vendor Relationships

Wise’s own 2025 engineering-blog disclosure of its technical stack lists Amazon Web Services (Transit Gateway, RDS, S3, SageMaker, Bedrock, EMR), Kubernetes/Rancher, MongoDB, Kafka, Snowflake, Trino, Airflow, the Grafana/Loki/Tempo/Mimir observability stack, Terraform, and CI/CD tooling (GitHub Actions, ArgoCD, Spinnaker), together with LLM access to Anthropic Claude, AWS Bedrock, Google Gemini and OpenAI ¹. No Israeli-origin cybersecurity, analytics, or enterprise-software vendor - including Check Point, Wiz, SentinelOne, CyberArk, NICE, Verint, Claroty, or Palo Alto Networks - is named anywhere in this vendor-by-vendor disclosure ¹. Wise’s FY2025 annual report, covering the year ended 31 March 2025, likewise contains no reference to Israel, Israeli vendors, named cybersecurity products, data centres, biometrics, or defence/military contracts in the sections reviewed ². No public evidence identified of a licensing, subscription, or integration relationship between Wise and any of the named Israeli-origin vendors, based on review of Wise’s engineering blog, annual report, job postings, and vendor case-study pages ¹². The one identified commercial partnership with an Israel-facing counterparty is a 2022 tie-up with Israeli platform Max, reported as opening Israeli consumers’ access to Wise’s global-payment service - this is a market-access/distribution partnership rather than a technology-procurement relationship, and no further detail on data-sharing or system integration was found ³. No public evidence identified of named systems integrators or IT consultancies engaged by Wise for major technology programmes, nor of any integrator mandating Israeli-origin technology on Wise’s behalf, based on review of the annual report, press releases, and general web search ².

Surveillance, Biometrics & Retail Technology

Wise’s Personal Customer Privacy Notice confirms that the company itself performs biometric identity verification, stating that it “extract[s] face scan information (known as ‘biometric data’) from a selfie or video that you provide to compare with the picture of you on identity documents” ⁴. The notice does not name a specific third-party vendor, referring only generically to “verification service providers” and “providers of fraud prevention services” ⁴. Wise’s Israel-specific verification guidance separately mandates video/biometric verification “to verify you in compliance with Israeli law,” citing Israel’s Anti-Money Laundering Act Article 7 and requiring an Israeli-issued identity document (Teudat Zehut, Israeli driving licence, or Israeli passport), again without disclosing any vendor name ⁵. No public evidence identified linking Wise to Trigo, BriefCam, AnyVision/Oosto, Trax, or comparable Israeli-origin facial-recognition or retail-analytics vendors; this category is not applicable in the conventional retail sense, since Wise has no physical retail footprint requiring in-store biometric or loss-prevention technology ¹. No public evidence identified of Wise use of Israeli-origin predictive-policing, sentiment-analysis, social-media-monitoring, or workforce-surveillance tools, based on general web search and review of Wise’s engineering and privacy disclosures ¹⁴. No public evidence identified of indirect or bundled delivery of Israeli-origin surveillance or biometric technology to Wise via managed-service or platform providers.

Cloud Infrastructure, Data Residency & Sovereign Cloud Participation

No public evidence identified that Wise operates, leases, or co-locates data-centre infrastructure within Israel; Wise’s disclosed infrastructure is AWS-based, and no Israel-region hosting is referenced in its technical or financial disclosures ¹². Wise ILS Ltd (company no. 515856110), registered at Derech Begin 121, Azrieli Sarona Tower, Tel Aviv-Yafo, is licensed by Israel’s Capital Market, Insurance and Savings Authority (CMISA) under the Supervision of Financial Services (Regulated Financial Services) Law – 2016, as a “Financial Asset Service Provider (Extended),” licence number 62727 ⁶⁷. This is a regulated financial entity - not a cloud-infrastructure entity - that permits Wise to plug its multi-currency payment engine into Israeli shekel (ILS) settlement rails ⁸. A live Wise Tel Aviv job posting for a “Compliance Senior Specialist” describes a “growing Israeli operation” with “statutory directors” and requires expertise in regulations issued by the Israel Securities Authority and CMISA, including alignment with a “new regulatory framework and new Payment Services Law” ⁹. This posting indicates an operating compliance/regulatory function in Israel rather than an engineering or cloud-infrastructure hub ⁹. No public evidence identified that Wise participates in Project Nimbus or any comparable Israeli state-backed cloud programme, based on review of the annual report, engineering blog, and general web search for “Wise” combined with “Nimbus” or “government cloud” ¹². No public evidence identified that Wise provides services explicitly marketed to ensure digital sovereignty, data residency, or infrastructure resilience for Israeli state or military institutions.

Defence, Intelligence & Security Sector Technology Relationships

No public evidence identified of any contract, partnership, or service agreement between Wise and the Israeli Ministry of Defence, the IDF, or Israeli intelligence agencies, based on review of the annual report and general web and procurement-record search ². No public evidence identified of Wise’s consumer money-transfer technology being reported, confirmed, or documented as deployed for military, intelligence, or law-enforcement surveillance applications in Israel or the occupied territories. No public evidence identified of Wise developing, selling, licensing, or maintaining offensive cyber capabilities, zero-day tools, or digital weapons systems, nor of any Israeli state deployment of Wise-originated tools. A targeted search of the OHCHR Special Rapporteur’s report “From economy of occupation to economy of genocide” (A/HRC/59/23, 2 July 2025) did not surface any Wise or TransferWise-specific mention; the report’s technology/finance sections concern cloud, AI, and major payment-rail providers rather than retail money-transfer fintechs ¹⁰.

AI, Algorithmic & Autonomous Systems

Wise’s disclosed AI/ML use - SageMaker, Bedrock, MLflow, Ray Serve, and LLM access to Claude, Gemini and OpenAI models - is applied to internal engineering functions such as a retrieval-augmented-generation (RAG) service and a prediction service, with no mention of provision to any government or state body in the company’s own tech-stack disclosure ¹. No public evidence identified of Wise providing AI/ML, computer vision, or decision-support systems to Israeli state, military, or security bodies. No public evidence identified that Wise’s AI models have been trained on, or granted access to, civilian population data, intercepted communications, or surveillance-derived datasets originating from Israel or the occupied territories. No public evidence identified of Wise providing autonomous target-generation, threat-detection, or tracking systems to Israeli military or security forces; Wise’s product domain of consumer and business cross-border payments has no described purpose-built targeting or kill-chain application.

Technology Ecosystem & R&D Footprint

Wise’s Tel Aviv presence, as evidenced by its job postings and its Wise ILS group-entity listing, is described in compliance and regulatory terms - a “growing Israeli operation” with compliance oversight of CMISA/Israel Securities Authority regulatory frameworks - rather than as an R&D, engineering, or innovation-lab function ⁹¹¹. No public evidence identified of a Wise R&D centre, engineering office, or accelerator programme in Israel. No public evidence identified of Wise acquiring any Israeli-origin technology company; Wise’s confirmed acquisition activity includes Expatica, a European expat-information platform, with no Israeli target identified in acquisition-history searches. No public evidence identified of strategic investment by the Wise corporate entity in Israeli technology startups or venture funds. Chair Alastair (Alex) Rampell’s disclosed board seats - spanning Branch, Brightside, Capitolis, Descript, Divvy Homes, Earnin, Flock Homes, FlyHomes, Loft, Point, Propel, Rocket Companies, Sentilink, Super Evil Megacorp, VGS, and Wise - do not include any Israeli surveillance, cyber, AI, SIGINT, or military-technology firm such as NSO, Cellebrite, Carbyne, AnyVision/Oosto, Wiz, Palantir, Check Point, SentinelOne, Verint, or NICE ¹². Review of Wise plc’s Board of Directors page found no Israel-related affiliations, investments, or defence-industry ties disclosed for other board members, including Hooi Ling Tan, Scott Hill, and Elizabeth B. Chambers, though this review was not exhaustive of each individual’s full investment and board history ¹³. No public evidence identified of significant patent portfolios, licensing agreements, or co-development arrangements between Wise and the Technion, Hebrew University, or the Weizmann Institute; general web search for Wise combined with these named institutions returned only unrelated Google/IBM–Technion collaborations.

Civil Society Scrutiny & Regulatory History

Authoritative-database screening: Wise, Wise plc, and TransferWise do not appear as a named entity in the OHCHR Database of Business Enterprises (per HRC resolutions 31/36/53/25) as indexed via OpenSanctions, which lists 156–158 entities as of its 2025 update; no construction, real estate, retail, or financial-services entry matching Wise was found ¹⁴. Wise does not appear in the Don’t Buy Into Occupation 2025 report’s company profiles or company list as searched in the full PDF ¹⁵. No public evidence identified of Wise or its named controlling principals appearing in Who Profits, AFSC Investigate, or predecessor UN Special Rapporteur reports.

Account freezes and financial exclusion of Palestinians: Following Novara Media’s investigation, conducted with Manara (a MENA tech-worker training network), Wise and Payoneer accounts belonging to Palestinians in Gaza, the West Bank, Israel, and the diaspora were frozen or restricted in the three weeks following 7 October 2023, with at least 20 individuals of a roughly 400-person Manara network reporting inability to access funds for basic necessities and medical care, most still blocked around two months later at the time of publication (3 January 2024) ¹⁶¹⁷. Wise’s public statement asserted that, “as a regulated financial institution, we provide our service, where permitted by law, to customers regardless of their personal characteristics, including their nationality,” and that account deactivation follows “a thorough review by our team” ¹⁷. To individual complainant Mariam Al-Najjar in the West Bank, Wise stated that due-diligence checks “may take up to 60 working days” and that “Wise has the right to close your account without notice” ¹⁷. Roula Hamdan, a dual-national Palestinian in southern Gaza, was blocked from account access for over two months at the time of reporting ¹⁷. The Business & Human Rights Resource Centre republished and sought company comment on these findings ¹⁶.

Legal action: The European Legal Support Center (ELSC), together with Brussels law firm Progress Lawyers Network, launched proceedings on behalf of two Palestinian women resident in Italy against Wise Europe SA before the Court of First Instance of Brussels, alleging breach of contract, abusive exercise of rights, violation of mandatory consumer-protection rules, and unlawful discrimination arising from October 2023 account closures ¹⁸. The complainants had held their accounts for over a year and relied on them for salary and expenses; Wise reportedly told them it could not disclose information “due to the way we are regulated” ¹⁸. The case is reported as active and ongoing, with ELSC and Progress Lawyers Network also soliciting further Palestinian testimonies of similar closures ¹⁸.

Sector-wide findings: A 7amleh (Arab Center for the Advancement of Social Media) report published 5 May 2026, examining roughly 30 digital platforms across Gaza, the West Bank, and Israel, found that “other global financial tech providers, such as Revolut, Stripe, Payoneer, and Wise, also exclude or severely limit Palestinian users,” contrasting this with the access available to Israeli citizens, including settlers in the West Bank, on comparable platforms ¹⁹²⁰. Wise (as TransferWise) appears on the boycott-tracking site boycottisraeli.biz under “Banking & Finance”/“Technology,” with stated grounds of “Froze Palestine accounts with no explanation,” citing the January 2024 Novara Media reporting ²¹.

Comparative conduct: Wise publicly waived transfer fees on donations to Ukraine-related charities - Save the Children, UNHCR, CARE, and the Ukraine Red Cross Society - following Russia’s invasion, stating: “This war is a tragedy and we stand with Ukraine and its people, including all our Wisers and their families and friends” ²². No comparable public fee-waiver or solidarity statement for Gaza or Palestinian customers was identified in this research, in the same broad period that Palestinian customer accounts were frozen without explanation following October 2023 ¹⁶¹⁷²².

Service availability: Wise’s official list of countries/regions it can send to does not include Palestine, the West Bank, or Gaza as a destination; Israel itself is also not listed among send-to destinations, though Wise ILS Ltd is separately licensed for local ILS-denominated account services ²³⁶.

Unrelated regulatory matter: Wise is under investigation by Belgian prosecutors, reported as at an “advanced stage, nearing conclusion” as of June 2026, over alleged anti-money-laundering control failures tied to approximately €500 million in suspicious transactions across 30 European countries; this investigation is not reported as Israel-related ²⁴. No public evidence identified of any regulatory inquiry, export-control action, or sanctions-related investigation specifically involving Wise’s technology sales or services to Israeli state entities.

End Notes