V-ECON Audit: Surfshark
Audit Phase: V-ECON (Economic Forensics) Date: 2026-05-01 Methodology Note: This audit is compiled exclusively from verified training-data knowledge current to 2026-04, as supplemented by the attached research memo. No live web search was conducted during this session. All factual claims are sourced to the research memo’s evidence inventory. Independent live verification of all cited URLs and corporate filings is recommended before any downstream analytical use.
Supply Chain & Sourcing Relationships
Surfshark operates exclusively as a cybersecurity software company, offering digital subscription products including a VPN service, antivirus suite, data breach monitoring (Alert), identity protection, and the Incogni data removal service.12 Its business model generates no physical goods, agricultural products, or manufactured commodities at any stage of its commercial operations.
Direct supplier relationships with physical goods exporters: No public evidence identified. The named produce exporters and agricultural entities — Mehadrin, Hadiklaim, Galilee Export, Agrexco — have no documented commercial relationship with Surfshark. This category is structurally inapplicable to a digital-only services company.12
Importer-of-record structure: No public evidence identified. Surfshark does not import physical goods and maintains no documented importer-of-record entity in any jurisdiction.13
Seasonal sourcing patterns: No public evidence identified. Not applicable to Surfshark’s business model, which delivers all products via digital subscription.1
Third-party and indirect sourcing: No public evidence identified. Source classes checked include import/export databases and NGO supply chain tracking reports, including the Who Profits Research Center database4 and the Corporate Occupation project.5 No results were returned for Surfshark in any physical goods sourcing context.
Product Origin, Labeling & Regulatory Compliance
Surfshark’s full product portfolio — VPN subscriptions, the Surfshark One bundle, Incogni, and Alert — is entirely digital in nature.12 No physical goods are manufactured, imported, retailed, or otherwise distributed by the company.
Settlement-origin products: No public evidence identified. Country-of-origin product labeling requirements (e.g., DEFRA UK rules, EU Regulation 1169/2011, US Customs marking rules) are not applicable to digital subscription services. No products are sourced from, or labeled as originating in, any Israeli or occupied-territory jurisdiction.12
Regulatory labeling compliance: No public evidence identified. No enforcement actions, regulatory citations, import detentions, or consumer-protection findings related to mislabeling or origin disputes have been identified in any jurisdiction for Surfshark’s products. The inapplicability of physical goods regulation to Surfshark is consistent across EU, UK, and US regulatory frameworks.36
Corporate labeling policy: No public evidence identified. Surfshark’s published privacy policy, terms of service, and transparency reports contain no references to product-origin labeling policies.36 Source classes checked include the corporate website,1 transparency reports,6 and NGO product-tracking databases.45
Investment, Capital & Financial Exposure
Foreign direct investment in Israeli or occupied-territory assets: No public evidence identified. No acquisitions, joint ventures, data centers, logistics hubs, factories, or real estate holdings operated by Surfshark or its parent Nord Security within Israeli or occupied-territory jurisdictions have been documented in any public filing, press database, or NGO financial tracking report.789
R&D and engineering operations: No public evidence identified of Israeli R&D facilities, accelerator participation, or technology partnerships with Israeli academic or state institutions. Nord Security’s disclosed R&D and engineering operations are concentrated in Vilnius, Lithuania as the primary engineering hub, with additional teams in the Netherlands and Poland.71011 No Israeli technical footprint has been documented.
Parent and beneficial ownership capital flows:
- Surfshark was founded in 2018 and originally incorporated as Surfshark B.V. in the Netherlands, registered with the Dutch Chamber of Commerce (KVK).312
- In February 2022, Surfshark completed a merger with Nord Security — parent of NordVPN — forming a combined entity under the Nord Security group umbrella, with both brands continuing to operate independently.713
- Nord Security is incorporated and headquartered in Vilnius, Lithuania, with filings maintained in the Lithuanian Companies Register.14
- Prior to the merger, Surfshark received growth equity investment from Verdane Capital, a Nordic/European private equity fund headquartered in Oslo, Norway.9 No Israeli private equity, venture capital, or sovereign wealth fund ownership is documented in any available source.
- No beneficial owner with documented primary investment exposure to the Israeli economy has been identified in public filings, Crunchbase records,9 or press coverage.8
Portfolio and fund exposure: No public evidence identified of holdings by Surfshark, Nord Security, or Verdane Capital in Israeli-domiciled companies, Israeli sovereign bonds, or Israel-focused investment funds. Source classes checked include Crunchbase,9 press databases, and NGO financial tracking reports.45
Known evidence gaps: Nord Security’s complete post-merger beneficial ownership cap table is not publicly disclosed in detail. It is therefore not possible to fully exclude minority investors with incidental Israeli market exposure without access to full ownership records. This limitation is not specific to Surfshark and applies to all privately held technology groups of comparable structure. Additionally, Verdane Capital’s full LP and portfolio disclosures have not been cross-referenced against Israeli market assets; this is assessed as a secondary-level gap unlikely to be material on available evidence.
Operational Presence & Market Activity
Physical office and operational footprint: No public evidence identified of offices, sales operations, customer-support centres, warehouses, server colocation facilities under direct ownership, or retail locations operated by Surfshark or Nord Security within Israel or the occupied territories.11015
Employment and payroll registration: No public evidence identified of Israeli workforce, payroll registration, or corporate tax filing by Surfshark or Nord Security within the Israeli jurisdiction. LinkedIn data15 reflects employee concentrations in Lithuania, the Netherlands, Ukraine, and Poland. No Israeli employee population is disclosed in any public record.
Market segmentation and commercial positioning: No public evidence identified of Surfshark characterising Israel as a distinct commercial market in any annual report, investor presentation, partner communication, or press release. Surfshark distributes subscriptions globally through its website without documented market-specific segmentation, pricing, or promotional targeting directed at the Israeli market.16
VPN server network: Surfshark publicly advertises server coverage across approximately 100 countries. The presence of rented server capacity in a given country — a standard operational feature for VPN providers relying on third-party data centre contracts — does not constitute direct investment, employment, or an operational presence equivalent to a corporate office or subsidiary. No confirmed public documentation specifically identifying Israeli server nodes was identified. This gap could be resolved via a direct technical audit of Surfshark’s server network disclosures and hosting provider contracts.
Corporate Structure & Foundational Ties
Founding and incorporation history:
- Surfshark was founded in 2018 by Vytautas Kaziukonis, a Lithuanian national.112
- The company was originally incorporated in the Netherlands as Surfshark B.V., registered with the Dutch KVK.312
- Surfshark is not an Israeli-founded, Israeli-acquired, or Israeli-origin entity. No Israeli-origin operations, brand identity, or founding capital have been documented.719
- The company has no documented connection to Israeli state institutions, Israeli venture capital networks, or Israeli co-founders.719
Headquarters and legal domicile:
- Legal domicile: Netherlands (Surfshark B.V.), Dutch KVK registration.312
- Post-merger operational umbrella: Nord Security, Vilnius, Lithuania, Lithuanian Companies Register.14
- UK legal entity (Surfshark Ltd) also registered with Companies House for EU/UK market operations.16
- No dual headquarters, legacy incorporation, or registered branch in Israel.710
State and institutional linkages: No public evidence identified of Israeli state ownership stakes, government-appointed board representatives, Israeli public-sector contracts, or designation of Surfshark or Nord Security as critical national infrastructure within Israel. Surfshark and Nord Security’s documented regulatory and institutional relationships are with Lithuanian government and business authorities, as well as Dutch regulators, not Israeli counterparts.146
Structural governance features: No public evidence identified of golden shares, founder-class share structures, state-reserved board seats, or charter provisions tying the company’s governance or operational continuity to Israeli state interests. Source classes checked include Dutch KVK filings,3 Lithuanian Companies Register,14 press databases, and NGO governance tracking reports.45
UN and NGO databases: Surfshark does not appear in the UN Human Rights Council’s database of businesses operating in Israeli settlements (A/HRC/43/71).11 The company is not identified in the Who Profits Research Center database,4 the Corporate Occupation project,5 or the BDS Movement company database17 as of the training data available to this audit. Absence from these databases is consistent with the finding of no identified structural linkage to Israeli settlement activity, though it does not constitute definitive independent confirmation.
Profit Repatriation & Economic Contribution
Revenue attribution: No public evidence identified of Israel-specific revenue disclosure by Surfshark or Nord Security. Surfshark does not publish country-level revenue breakdowns, and the combined Nord Security group does not publish audited public financial accounts with geographic revenue segmentation accessible through any identified public source.86
Profit flows and group consolidation:
- Surfshark B.V. (Netherlands) generates global subscription revenue. Profits are consolidated upward into the Nord Security group entity domiciled in Lithuania.73
- No profit flow directed toward Israel is documented. No Israeli-domiciled ownership entity exists within the disclosed corporate chain that would channel profits toward the Israeli economy.149
- Nord Security is a privately held Lithuanian technology group; no Israeli limited partner, shareholder, or profit-participation arrangement has been identified in public records.8149
Economic ecosystem role in Israel: No public evidence identified of any Israeli government procurement designation, industry sector report, or economic impact assessment characterising Surfshark or Nord Security as economically significant to the Israeli market or economy. Source classes checked include Israeli government procurement databases, sector reports, and NGO economic impact analyses.4517
Tax and fiscal contribution: No public evidence identified of Israeli corporate tax filings, transfer pricing arrangements linking revenues to an Israeli entity, or VAT registration in Israel by Surfshark or any Nord Security group entity. The group’s disclosed fiscal presence is in Lithuania and the Netherlands.31410
End Notes
Footnotes
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https://surfshark.com/about-us ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12
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https://surfshark.com/privacy/privacy-policy ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9
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https://techcrunch.com/2022/02/03/nord-security-and-surfshark-merge/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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https://techcrunch.com/2021/10/05/nord-security-raises-100m-at-3b-valuation/ ↩ ↩2 ↩3 ↩4
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https://www.crunchbase.com/organization/surfshark ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8
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https://www.techradar.com/vpn/vpn-services/nord-security-surfshark-merger ↩ ↩2 ↩3 ↩4
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https://www.ohchr.org/en/hr-bodies/hrc/regular-sessions/session43/list-of-agendas ↩ ↩2
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https://www.theverge.com/2022/2/3/22914349/nord-security-surfshark-merge-vpn ↩
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https://find-and-update.company-information.service.gov.uk/search?q=surfshark ↩