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Military-Affiliated Students: Managing International Compliance When Duty Calls

By Bill Ferreira, Stephanie Gold, and Megan Wilson


When colleges and universities offer online programs internationally, often it’s within the framework of expansion – attracting non-U.S. students and increasing global footprint. However, U.S.-based students already enrolled at the institution may move to locations abroad for various reasons, prompting the school to consider how best to facilitate the transition. This is especially true for military-affiliated students who are posted to U.S. military bases and other installations outside the United States.

While federal law allows U.S. service members to return to an institution without penalty if their education has been disrupted by service obligations, some students may want to continue their education program abroad through the school’s online education platform. Individuals who are partners or dependents of service members similarly may want to leverage synchronous and asynchronous course offerings to avoid disruption to their studies. How, then, can institutions ensure that military-affiliated students are suitably supported while also balancing legal requirements associated with international online programs?

The challenge is that U.S. schools generally remain subject to country-specific regulation even when making online programs available to students involved with U.S. defense operations in that country. An effective compliance strategy typically depends on the specific circumstances of the online offering and the country in which the student is located. As a result, country-by-country diligence is hard to avoid. We offer below three considerations for institutions faced with military-affiliated students who relocate abroad for service obligations and want to continue their education program online.

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Booked Marked Sections:

  • Introduction
  • Recognize that non-U.S. law may affect obligations.
  • Appreciate the complexity of U.S. military relationships with foreign countries.
  • Gauge the international compliance infrastructure and support framework.


Authors:  Generously provided to WCET/SAN by our colleagues at Hogan LovellsPlease review their individual biographies.

William F. FerreiraPartner, Washington DC, Phone: 202 637 5596, Email:

Stephanie GoldPartner, Washington DC, Phone: 202 637 5496, Email:

Megan WilsonSenior Associate, Washington DC, Phone: 202 637 7565, Email: