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John E. Turlais

Of Counsel

John E. Turlais

Of Counsel

John Turlais is a member of Foley & Lardner LLP’s Government Enforcement Defense & Investigations Practice Group. His practice focuses on international trade and customs law, advising clients on tariff classification, duty mitigation strategies, valuation and origin issues, and enforcement matters before U.S. Customs and Border Protection (CBP). He regularly assists companies in navigating complex import compliance requirements, preparing and submitting prior disclosures, responding to CBP inquiries and audits, and managing corrective actions related to Section 232 and Section 301 tariffs, country-of-origin marking, classification, and forced-labor issues.

In addition to his customs work, John advises clients on broader international trade compliance, including export controls under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), economic sanctions administered by the Office of Foreign Assets Control (OFAC), and anti-bribery/anti-corruption (ABC) compliance under the Foreign Corrupt Practices Act (FCPA).

John also has significant experience conducting international compliance risk assessments and designing and improving compliance programs for companies of all sizes – from multinational corporations with established programs to small and mid-sized firms expanding globally. He frequently helps clients develop or enhance their internal controls, due diligence processes, and employee training programs tailored to their specific trade and regulatory risk profiles. John also has extensive experience conducting internal investigations and defending clients facing enforcement actions by the U.S. Department of Justice and other federal agencies.

John provides clients with practical, risk-based guidance and designs implementable international trade and ABC compliance solutions suited to clients’ needs and budgets. In recognition of his work developing tools to help mid-sized companies assess corruption risks and respond to issues more efficiently and effectively, John has received the State Bar of Wisconsin’s Legal Innovator award and the Milwaukee BizTimes’ I.Q. (Innovation Quotient) award.

John understands that it is critically important to have a coordinated, multijurisdictional response to multinational enforcement actions. To that end, he helped establish an international defense alliance, the ConciliumTM Global Network, composed of compliance, investigations, and government enforcement defense attorneys located in countries around the world. John also serves as the FCPA advisor to a software firm developing online ABC modules specifically designed for training multinational companies operating in India.

John is a frequent writer and speaker on topics related to the international trade compliance, internal investigations, and cross-border government defense strategies. For a list of his publications, please see the Insights section below.

Before joining Foley, John co-founded ProjectLearn USA, Inc., an educational company that provided information and strategies on developing study practices and test-taking skills. John also played professional baseball in the Pittsburgh Pirates and New York Mets organizations.

Awards and Recognition

  • State Bar of Wisconsin, Pro Bono Honor Society
  • State Bar of Wisconsin, Legal Innovator award
  • Milwaukee BizTimes, I.Q. (Innovation Quotient) award
  • Wisconsin Super Lawyers® – Rising Star (2011–2013)

Community Involvement

  • Member of the board of directors of Broadscope Disability Services
  • Past member of the board of directors of the Oak Creek Girls Youth Basketball Association
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 13, 2026 Tariff & International Trade Resource

What Every Multinational Should Know About …Managing the Aftermath of the Supreme Court’s Historic IEEPA Tariff Decision (Part VI)

For companies that acted as importers of record, the most immediate risk is procedural: failing to take the steps necessary to preserve and secure refund rights. The Supreme Court’s decision does not automatically result in refunds, and the process will be shaped by ongoing litigation at the CIT and potential administrative actions.
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 13, 2026 Blogs

What Every Multinational Should Know About…Managing the Aftermath of the Supreme Court’s Historic IEEPA Tariff Decision (Part V)

The conundrum for companies that indirectly paid the IEEPA tariffs, such as those that re-ceived price increases or outright tariff surcharges, is that the importing system is set up so that all refunds will be made by CBP directly to the importer of record. Nonetheless, compa-nies that indirectly paid the IEEPA tariffs may have contractual options, or potentially can use commercial leverage, to seek a refund of some or all of the price increases.
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 13, 2026 Tariff & International Trade Resource

What Every Multinational Should Know About…Managing the Aftermath of the Supreme Court’s IEEPA Tariff Decision (Part IV)

Importers of record need to ensure they are best positioned to secure any refunds, while also adapting to the new replacement tariffs. Therefore, on the customs side, we recommend the following steps for importers of record dealing with these issues.
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 11, 2026 Tariff & International Trade Resource

What Every Multinational Should Know About…Managing the Aftermath of the Supreme Court’s IEEPA Tariff Decision (Part III)

The importer of record is the entity that initially pays all tariffs and thus is the entity that would receive any IEEPA tariff refunds. Nonetheless, behind the scenes there often are a variety of mechanisms importers of record may have used to handle the often unexpected tariffs, including pushing back on suppliers for price concessions, using surcharges to pass along tariffs, or generally increasing price. In many cases, other parties may be looking to share any potential refunds.
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 10, 2026 Tariff & International Trade Resource

What Every Multinational Should Know About…Managing the Aftermath of the Supreme Court’s IEEPA Tariff Decision (Part II)

On February 20, 2026, the U.S. Supreme Court issued its long-anticipated decisions in Learning Resources, Inc. v. Trump, and the consolidated case Trump v. V.O.S. Selections, Inc., holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose broad-based tariffs.
The image shows the facade of the United States Supreme Court building, featuring Corinthian columns and sculpted figures above the entrance—a symbol of justice often referenced by Chicago lawyers specializing in intellectual property law.
March 10, 2026 Tariff & International Trade Resource

What Every Multinational Should Know About …Managing the Aftermath of the Supreme Court’s Historic IEEPA Tariff Decision (Part I)

The Supreme Court’s reversal of tariffs imposed pursuant to the International Emergency Economic Powers Act (IEEPA) has triggered a cascading series of events. These include a forced pivot by the Trump administration towards alternative tariff authorities, activity at the Court of International Trade (CIT) aimed at securing refunds, and behind-the-scenes jockeying by companies seeking to position themselves to claim those tariff refunds.