BDS-1000 Dossier: HSBC Holdings plc

Key Findings

• Economic: HSBC provided $14.21 billion in loans and underwriting to settlement-linked companies between 2020 and 2023, ranking among the top European creditors; it led €1 billion in financing for the Tel Aviv Purple Line involving Shapir Engineering, which operates the Jerusalem Light Rail Red Line serving illegal settlements.¹²
• Military: HSBC maintained holdings in Caterpillar Inc. (£99M), whose D9 bulldozers are documented in Palestinian home demolitions; it re-acquired Elbit Systems shares ($8.3M) in late 2025 before achieving full divestment in May 2026 following sustained direct action campaigns.³⁴⁵
• Digital: HSBC deploys NICE Actimize (Israeli AML surveillance), CyberArk (privileged access management, R&D in Be’er Sheva), and BioCatch (Israeli behavioural biometrics) as operational technology at core infrastructure levels.⁶³²
• Not found: HSBC is not listed in the UN OHCHR database of businesses involved in Israeli settlements (2025 update) and is not among the seven underwriters of Israeli sovereign bonds.⁴²

Target Profile

Executive Summary

HSBC Holdings plc, one of the world’s largest banking institutions, maintains significant financial relationships with entities implicated in Israel’s occupation of Palestinian territories. The bank’s documented involvement spans three primary vectors: direct financing of settlement-linked infrastructure projects, equity investments in defence contractors supplying the Israeli military, and operational technology dependencies on Israeli-origin security platforms.

The strongest evidence of complicity centres on HSBC’s economic footprint. The bank provided $14.21 billion in loans and underwriting to settlement-linked companies between 2020 and 2023, ranking among the top European creditors to such entities. HSBC led €1 billion in financing for the Tel Aviv Purple Line light rail, a project involving Shapir Engineering - a company operating the Jerusalem Light Rail Red Line serving illegal settlements in East Jerusalem. The bank also maintained holdings in Caterpillar Inc. (approximately £99 million), whose D9 bulldozers are documented in widespread use for Palestinian home demolitions.

Military-related exposure includes historical holdings in Elbit Systems, Israel’s largest defence electronics company. HSBC initially divested in 2018 following BDS campaign pressure, re-acquired 16,317 shares (valued at $8.3 million) by November 2025, and achieved full divestment only after sustained direct action campaigns in late 2025 and early 2026. The bank also maintains financing relationships with F-35 supply chain participants BAE Systems and Lockheed Martin, and general corporate financing with Raytheon.

Notably, HSBC has not been named in the UN OHCHR database of businesses involved in Israeli settlements (2025 update), and the bank is not an underwriter of Israeli sovereign bonds. The bank’s silence on the ICJ Advisory Opinion (July 2024) and ICC arrest warrants (November 2024) contrasts with its explicit statements on Russia’s invasion of Ukraine.

The resulting BRS score of 608 places HSBC in Tier B (Severe), driven primarily by substantial economic financing of settlement infrastructure and sustained defence sector investment.

Timeline of Relevant Events

Corporate Overview

HSBC Holdings plc is incorporated in England and Wales and operates as a universal bank with presence in over 50 countries. The group traces its origins to The Hongkong and Shanghai Banking Corporation, founded in 1865.

Israeli Operations: HSBC Bank plc maintains a full commercial banking licence in Israel, operating from Amot Atrium Tower, Ramat Gan. The Israeli operation offers corporate banking, innovation banking (serving tech and life science startups), and private banking services. Following the 2023 acquisition of Silicon Valley Bank UK, HSBC absorbed five senior managers from SVB Israel, including David Cohen and Gadi Moshe.

Subsidiaries and Structure: HSBC Bank Middle East Limited operates across the UAE, Saudi Arabia, Bahrain, Kuwait, Oman, Qatar, and Egypt - but not in the Occupied Palestinian Territories. No Israeli-domiciled subsidiaries or franchise relationships were identified beyond the Ramat Gan commercial banking operation.

Technology Dependencies: HSBC deploys multiple Israeli-origin technology platforms at core operational levels: NICE Actimize (Israeli AML and trade surveillance) for regulatory compliance infrastructure; CyberArk (privileged access management with R&D in Be’er Sheva, Israel); and BioCatch (Israeli behavioural biometrics) for fraud detection. These represent operational technology dependencies rather than corporate structure ties.

Domain Summaries

Military: Military

Mechanism of Involvement

HSBC’s military-related involvement operates through three primary mechanisms: equity investments in defence contractors, financing of infrastructure serving military/logistical functions, and correspondent banking relationships with Israeli financial institutions.

The most significant exposure involves equity holdings in companies supplying the Israeli military. HSBC maintained approximately £99 million in Caterpillar shares - equipment whose D9 bulldozers are documented in Palestinian home demolitions in the West Bank and Gaza. Norway’s Government Pension Fund Global divested $2.1 billion in Caterpillar shares, with the Council on Ethics stating “no doubt that Caterpillar’s products are being used to commit extensive and systematic violations of international humanitarian law.”⁴

HSBC’s defence sector investment totals approximately £831 million across firms supplying Israel, including BAE Systems (15% of each F-35 airframe), Lockheed Martin (prime F-35 contractor), and Raytheon (joint venture with Rafael for Iron Dome production).¹¹¹⁹

The Tel Aviv Purple Line financing connects HSBC to infrastructure projects with settlement-adjacent routing, while correspondent banking relationships with Bank Hapoalim and Bank Leumi provide financial infrastructure to institutions that finance settlement economic activity.¹¹²

Counter-Arguments and Evidence Limits

HSBC’s strongest defence centres on its May 2026 full divestment from Elbit Systems, representing a complete exit from direct defence contractor equity. The bank has not been identified as a primary lender in Caterpillar’s $3.5 billion syndicated credit facility - participation by HSBC in that specific facility remains unconfirmed.¹³ No public evidence was identified of direct contracts with the Israeli Ministry of Defence, IDF, Israel Prison Service, or Israel Border Police.⁷¹⁴

HSBC’s Defence Equipment Policy Statement (June 2024) prohibits financing for cluster munitions, white phosphorus, nuclear weapons, and lethal autonomous weapons, applying proportionately based on client “business mix, organisational structure and governance.”¹⁵ This policy provides interpretive flexibility for mixed-use defence contractors but establishes a formal exclusion framework.

The temporal context matters: HSBC’s Elbit re-investment occurred after the July 2024 ICJ Advisory Opinion and November 2024 ICC arrest warrants, but the bank ultimately achieved full divestment. The Caterpillar investment persists despite documented civil society calls for disengagement.

Named Entities and Evidence Map

Digital: Digital

Mechanism of Involvement

HSBC’s digital infrastructure involvement with Israeli entities operates through technology vendor relationships at core operational levels rather than direct digital infrastructure in Israel.

The bank deploys BioCatch, an Israeli-origin behavioural biometrics company, for fraud detection across US, UK, and Asia-Pacific operations. HSBC participates as a member of BioCatch’s Client Innovation Board alongside American Express, Barclays, Citi, and National Australia Bank, indicating a deeper collaborative relationship beyond mere procurement.²¹³

HSBC uses CyberArk for privileged access management (PAM), with the vendor maintaining R&D facilities in Be’er Sheva, Israel. This PAM deployment governs access to production banking systems and represents a foundational identity-security dependency.³

The Google Cloud AML AI platform processes approximately 1.2 billion transactions monthly for HSBC in the UK and Hong Kong, constituting a mission-critical compliance infrastructure.¹⁰ Google Cloud’s me-west1 region (located in Israel/Tel Aviv) launched in November 2022 and forms part of Project Nimbus. However, no public evidence confirms whether HSBC workloads traverse the Israeli cloud region.¹⁶⁶

NICE Actimize, an Israeli-origin AML and trade surveillance platform, is embedded at the core of HSBC’s regulatory compliance infrastructure.⁶

Counter-Arguments and Evidence Limits

No public evidence was identified confirming HSBC operates, leases, or co-locates data centre infrastructure within Israeli territory. The HSBC Israel operation functions as a commercial banking presence rather than infrastructure hosting.⁴⁸

No public evidence was identified confirming HSBC participation in Project Nimbus or any Israeli government cloud initiative. Project Nimbus involves Google, Amazon, and the Israeli government for government workloads - HSBC, as a commercial banking institution, is not a party to this governmental procurement.⁶

No public evidence was identified confirming HSBC provides AI, ML, or autonomous decision-support systems to Israeli state bodies, military institutions, or security services. The bank’s AI applications remain confined to financial services (fraud detection, AML, customer service automation).

No public evidence was identified of BDS or civil society campaigns specifically targeting HSBC’s technology vendor relationships with Israeli-origin firms.

Named Entities and Evidence Map

Economic: Economic

Mechanism of Involvement

HSBC’s economic involvement with Israel and the occupied territories represents the strongest documented vector of complicity. The bank operates a full commercial banking licence in Israel (since 2001) and provides substantial financing to settlement-linked infrastructure and companies.

The €1 billion Tel Aviv Purple Line financing, led by HSBC in partnership with Bank Leumi, represents direct infrastructure financing. Shapir Engineering, the construction partner, operates the Jerusalem Light Rail Red Line serving illegal settlements including Pisgat Zeev and Neve Yaakov in East Jerusalem.¹¹⁶

The DBIO Coalition reports document HSBC as among the top European creditors to settlement-linked companies, providing $14.21 billion in loans and underwriting between 2020 and 2023.²⁸⁹ This ranking places HSBC fourth among European financial institutions for such financing.

HSBC’s correspondent banking relationships with Bank Hapoalim, Bank Leumi, Israel Discount Bank, and Mizrahi Tefahot provide cross-border payment processing and trade finance services to Israeli banks that, in turn, provide mortgage, business, and infrastructure lending within Israeli settlements.¹²

The bank’s innovation banking operation in Israel serves venture-backed technology and life science businesses, with the Techstars partnership announced March 2024.⁵¹⁸

Counter-Arguments and Evidence Limits

HSBC was NOT among the seven underwriters for Israeli sovereign bond issuances ($19.4 billion, October 2023–January 2025). The syndicate consisted exclusively of Goldman Sachs, Bank of America, Deutsche Bank, BNP Paribas, Citi, Barclays, and JPMorgan.²

HSBC is NOT listed in the UN OHCHR database of 158 businesses involved in Israeli settlements (2025 update).⁴⁷

HSBC does not disclose standalone Israel revenue in geographic segment reporting - Israel does not appear as a named country unit in HSBC’s business line or regional reporting clusters.

The bank’s May 2026 full divestment from Elbit Systems represents a complete exit from direct defence contractor equity holdings.

Named Entities and Evidence Map

Political: Political

Mechanism of Involvement

HSBC’s political involvement manifests primarily through institutional silence on the October 2023 events and subsequent military operations, contrasted with explicit statements on other geopolitical conflicts.

The bank issued no standalone corporate statements specifically addressing the October 2023 Hamas attack or subsequent Israeli military operations in Gaza through early 2025. This approach aligns with HSBC’s stated “political neutrality” framework for contested geopolitical conflicts not directly affecting operating licences - a posture consistent with its positioning during the 2019-2020 Hong Kong protests.¹⁰

A notable disparity exists between HSBC’s response to Ukraine and Gaza. The bank issued formal statements condemning Russia’s invasion of Ukraine in February 2022, announced suspension of new business in Russia and Belarus, and absorbed approximately $300 million in write-downs. No equivalent positioning was adopted for Gaza.¹⁰

Following the ICJ Advisory Opinion (July 2024) determining Israel’s occupation unlawful, no confirmed HSBC statement was identified revising investment or financing posture. Similarly, following ICC arrest warrants (November 2024), no confirmed HSBC statement was identified.¹⁰

No public evidence was identified of HSBC political donations to UK political parties, Israel-specific lobbying, or executive personal philanthropy to Israeli advocacy organizations.¹⁰

Counter-Arguments and Evidence Limits

HSBC is NOT listed in the UN OHCHR database of businesses involved in Israeli settlements (2025 update).⁴⁷

HSBC is NOT an underwriter of Israeli sovereign bonds - the seven identified underwriters are Goldman Sachs, Bank of America, Deutsche Bank, BNP Paribas, Citi, Barclays, and JPMorgan.²

No confirmed board member personal memberships in pro-Israel organisations (AIPAC, CFI, BICOM, ADL) were identified among HSBC board members.⁸

HSBC’s Code of Conduct (updated October 2024) instructs employees to avoid actions that could be interpreted as taking political stances on contested geopolitical matters. This policy is general and not specific to any particular conflict.¹⁴

The bank’s full divestment from Elbit Systems (May 2026) represents a response to civil society pressure, though this occurred after the ICJ and ICC developments.

Named Entities and Evidence Map

BDS-1000 Score (V4)

• V_MAX: 8.00 (Economic)
• Sum_OTHERS: 8.63
• BRS Score: 608 Tier: B (Severe)

The Economic domain drives the maximum score, reflecting HSBC’s substantial documented financing of settlement-linked infrastructure ($14.21 billion, 2020–2023) and the €1 billion Tel Aviv Purple Line project involving settlement-serving entities. The tier classification reflects severe documented involvement across economic and military vectors, tempered by the bank’s full divestment from Elbit Systems and absence from the UN OHCHR settlement database. The scoring methodology applies scale-free Impact × Magnitude/Proximity calculations using evidence-only from the four domain audits, with human-vetted final scores.

Methodology Note

• Evidence-only basis: All factual claims derive from the four domain audit documents (Military, Digital, Economic, Political). No external sources were introduced.
• Scale-free Impact calculation: Impact (I) reflects activity type - economic financing of settlement infrastructure scores highest (8.0); direct defence investment and political silence score moderate (5.5–6.0); digital technology vendor relationships score lower (3.5).
• Magnitude/Proximity (M): Magnitude reflects documented financing volumes ($14.21B) and investment values (£831M defence, £99M Caterpillar). Proximity reflects direct operational presence (full banking licence) and infrastructure project involvement.
• Directness (P): Directness captures the proximity of the activity to the occupation - settlement infrastructure financing (8.5), defence equity holdings (6.5), technology vendor relationships (3.5), corporate silence (5.0).
• Temporal rule: Divested or exited operations are scored based on the audit period; HSBC’s full Elbit divestment (May 2026) is reflected in the assessment.
• Entity attribution: No transitive guilt - scoring reflects HSBC’s direct documented activities, not those of customers or counterparties beyond confirmed financing relationships.
• Settlement operation dual-counting: Infrastructure serving settlements counts in both Economic and Political where applicable.
• “No public evidence identified”: Used where audit checks found nothing - this represents a finding of absence, not a claim of innocence.

End Notes