Main Menu
ع
Don’t Buy into Occupation V report November 2025: The Private Actors Behind the Economy of Occupation and Genocide
Don’t Buy into Occupation V report November 2025: The Private Actors Behind the Economy of Occupation and Genocide
25، Nov 2025
Don’t Buy into Occupation V report November 2025: The Private Actors Behind the Economy of Occupation and Genocide

Executive Summary

Since 2021, the Don’t Buy into Occupation (DBIO) Coalition – a network of 25 Palestinian and European civil society organisations – has published four consecutive annual reports that expose the financial relationships between European financial institutions and businesses involved in Israel’s illegal settlement enterprise in the occupied West Bank, including East Jerusalem.

Previous reports were based on the database of business enterprises (“UN Database”) published by the Office of the United Nations High Commissioner for Human Rights (OHCHR). The mandate for the UN Database, issued by the Human Rights Council in March 2016, includes a list of 10 types of business activity related to illegal Israeli settlements in the Occupied Palestinian Territory (OPT) that raise particular human rights concerns (referred to as “listed activities”). These include the supply of materials and equipment facilitating the construction and expansion of illegal settlements; the supply of equipment for the demolition of housing and property; the provision of security services to enterprises operating in settlements; and the provision of banking services and financial operations for settlement-related projects. The first four DBIO reports have drawn both on the UN database and the online corporate database of Who Profits, the independent research centre based in Israel, while retaining the UN database’s “listed activities” as a key reference. The current, fifth, report draws on the Who Profits database as well as the Investigate database of the Action Center for Corporate Accountability of the American Friends Service Committee (AFSC). Due to the delay in publication of the latest update of the UN database, the current report draws on previous UN database listings and many, but not all, of the 158 companies included in the update.

In recent years, the situation in the OPT has changed significantly and dramatically in connection with Israel’s regime of occupation and apartheid against the Palestinian people as a whole, as well as Israel’s genocidal war in Gaza. Major legal determinations have been issued by international institutions, including the International Court of Justice (ICJ). In response to these developments, this fifth report (DBIO V) adopts a broader and more comprehensive approach than previous editions. It no longer limits its scope to companies linked to the illegal settlement enterprise in the West Bank, but also examines the financial relationships between European financial institutions and companies involved in other activities that support the maintenance of the illegal situation created by Israel in the OPT, including actions identified as genocide and other severe violations of international law.

This expansion in scope is grounded in a series of recent international legal findings that have further clarified the unlawful nature of Israel’s activities in the OPT, and the corresponding responsibilities of third states and private actors. On 19 July 2024, the ICJ issued an Advisory Opinion, declaring Israel’s occupation of Palestinian territory unlawful in its entirety and identifying breaches of key international norms. Specifically, the ICJ found that Israel’s entire ongoing presence in the OPT violates several fundamental, non-derogable principles of international law – known as jus cogens norms – including the prohibition of denial of the right of the Palestinian people to self-determination; the prohibition on acquiring territory by force (annexation); and the prohibition on racial segregation and apartheid.

Under international law, violations of such jus cogens norms create obligations for all other states, known as Third State responsibilities. This means that no state may recognize, assist or contribute to maintaining an illegal situation. In addition, under international human rights and humanitarian law any business activity that supports or benefits from Israel’s illegal presence in the OPT may also be considered in violation of these core international obligations. This principle has gained renewed urgency following two further legal developments. In January 2024, the ICJ issued provisional measures in application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel). In September 2025, the UN Independent International Commission of Inquiry on the occupied Palestinian territory, including East Jerusalem, and Israel (UN COI) concluded, based on its mandate and investigation, that Israel has been committing genocide

in Gaza. The UN COI’s September 2025 assessment marks a turning point – it is the first investigative UN body to have formally made the determination that Israel’s activities in Gaza have led to further violations of jus cogens norms in relation to the prohibition of genocide.

Together, these legal findings underscore the expanding scope of responsibility for Third States and private actors alike. They reinforce the need for companies, investors and Third States to assess whether their activities, partnerships or financial flows contribute, directly or indirectly, to the maintenance of Israel's unlawful presence in the OPT, including its commission of acts that amount to genocide and apartheid.

As previous DBIO reports have asserted, international businesses and financial institutions doing business in or connected to the Israeli settlement enterprise in the OPT have long failed to uphold both their international human rights responsibilities and their obligation to respect international law. Recent on-the-ground developments and newly issued international legal responses to these developments, however, have both heightened existing risks in relation to the settlement enterprise and generated a series of new risks for all businesses and financial institutions whose operations link them to Israel’s genocide in Gaza and/or occupation of the OPT. Companies are recognized as having obligations under international human rights and humanitarian law, i.e., according to the Geneva Conventions, the Hague Regulations, the Genocide Convention, among other human rights treaties. In other words, companies—along with their executives, board members, and employees—may be held directly and/or indirectly responsible for international crimes and human rights violations. The authoritative United Nations Guiding Principles on Business and Human Rights (UNGPs) and the Organization for Economic Cooperation and Development Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines) elaborate on the human rights responsibilities of corporate entities and provide the framework to assess their conduct.

Against this background, the current report uses an expanded list of categories and “listed activities”, which are based on the following authoritative legal rulings and resolutions:

  • The January 2024 determination by the International Court of Justice (ICJ) that Israel is plausibly violating the Genocide Convention in Gaza, as well as the September 2025 UN COI report stating that Israel is committing genocide;

  • The July 2024 ICJ Advisory Opinion determining that Israel’s entire occupation of Gaza and the West Bank, including East Jerusalem, is illegal and that Israel is violating the prohibition against racial segregation and apartheid in the International Convention on the Elimination of all Forms of Racial Discrimination (CERD);

  • The UN Human Rights Council (UN HRC) parameters used in determining the complicity of corporations implicated in Israel’s illegal settlement enterprise in the occupied Palestinian territory and included in its database;

  • The UN HRC resolution of April 2024 calling for a military embargo on Israel (reiterated in an April 2025 resolution by the UN HRC);

  • The UN General Assembly resolution of September 2024 calling on States to refrain from aiding or assisting the maintenance of Israel’s illegal occupation, as defined by the ICJ;

  • Authoritative statements and reports by UN special committees, UN human rights experts, and the UN Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967.

Click here to read the full report.