When does an association become an international organization?
Is it when it opens an office overseas? Establishes its first international chapter? Hires someone in another country?
Perhaps these are the wrong milestones to focus on. An association can be engaged internationally long before it establishes a formal presence abroad. And some activities that seem entirely routine can carry legal implications that leadership hasn't considered.
Take a virtual educational program, for example. Your association organizes a webinar from its US headquarters, invites an American speaker, and opens registration to professionals around the world. It's a relatively simple way to expand your audience without investing in an international operation.
But what happens when participants from Europe register and provide personal information? Could your association have obligations under the European Union's General Data Protection Regulation (GDPR)? Depending on the circumstances, potentially yes.
This was one of several examples Dorothy Deng, an attorney who advises associations and nonprofits, raised during a recent conversation on The Helm, a new podcast from Global Navigators on strategy, growth, and leadership. It points to something association executives should reconsider: International responsibilities aren't necessarily determined by where an organization is located. They may also be shaped by where its activities reach.
The risks aren't always where you'd expect them
Consider another familiar situation. Your association invites an expert from an overseas university or hospital to speak at a conference. You offer an honorarium or agree to cover travel expenses. Nothing particularly unusual about that. Except, as Dorothy explained, that individual may qualify as a foreign government official under US law, depending on their institution and circumstances. Suddenly, a routine speaker arrangement raises questions about compliance with the Foreign Corrupt Practices Act.
Or perhaps your association is exploring a partnership with a local organization to deliver educational programs abroad. The opportunity seems promising, and leadership is eager to move forward. But have you considered how the partner is legally structured? Whether your US tax-exempt status has any relevance locally? Which laws might govern the relationship? These aren't reasons to abandon an opportunity. They're reasons to ask better questions before making commitments.
International strategy needs a wider lens
Much of international growth planning focuses on market demand, partnerships, membership opportunities, and the resources needed to succeed. These are essential considerations. But the responsibilities that accompany international activities deserve attention, too.
It's easy to focus on the exciting questions: Where can we grow? Who should we partner with? What programs could we introduce? The less exciting questions sometimes receive attention much later, after decisions have been made and commitments established. That's a mistake.
Dorothy emphasized that organizations working internationally may need to consider legal requirements in both their home country and the foreign jurisdictions where they conduct activities. Those requirements can differ considerably, making local legal counsel an important resource. She also challenged the assumption that involving lawyers early will slow progress. Good legal counsel, she argued, should explain available options, identify risks, and help leadership understand possible paths forward. The decisions remain with association leadership.
It's an important distinction. Legal considerations should inform international strategy while it is being developed, rather than become a final checkpoint after the direction has already been decided.
Perhaps it's time to redefine your international footprint
For years, associations have measured their global presence through international membership numbers, overseas chapters, conferences, and partnerships. These are useful indicators, but they don't necessarily capture the full extent of an organization's international activities. An association with no international employees may have thousands of overseas learners. An organization without a foreign chapter may regularly collaborate with international institutions. A US-based society may collect data and deliver services to professionals across multiple jurisdictions. In each case, the organization may be more internationally active than its traditional measures suggest.
Perhaps it's time to stop treating international compliance as something that becomes relevant only after formal expansion. It deserves consideration as soon as international activities begin, even when those activities seem modest. That doesn't mean every webinar requires an extensive legal review or that every international opportunity presents substantial risk. It means recognizing when an activity warrants additional questions and knowing when to seek advice.
International growth often begins with small steps. Understanding the responsibilities attached to those steps can help associations pursue opportunities with greater confidence. So before asking whether your association is ready to expand internationally, consider another question:
How international are we already, and have we thought through what that means?
Leadership Voices
Featuring Dorothy Deng, Partner, Whiteford, Taylor & Preston LLP
“One of the largest unintentional legal risks, especially for international and global issues, is simply not being aware that cross-border legal issues do exist, with virtual programming as an example. If you have data subjects providing personal data that's largely based in Europe, even though you are recording or having the webinar speaker speaking in the United States, you may need to consider whether or not GDPR applies to your organization. Just because you're running an event that's from the headquarters in the United States, that doesn't exempt you from compliance depending on the audience and the nature of the activity.”
This newsletter is intended for general informational purposes only. The ideas and examples shared are illustrative and not specific recommendations for any one organization or individual. Because success in international markets looks different for every organization, we work with each client to identify solutions tailored to their goals and opportunities.
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