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. He has significant experience conducting international compliance risk assessments for domestic and foreign companies and, based on their specific risk profiles, designing and improving their international trade and anti-bribery/anti-corruption (ABC) compliance programs consistent with the expectations set forth by U.S. law enforcement agencies. He has worked with companies of all sizes —including publicly-traded companies and multinational corporations with established compliance programs, and small and mid-sized firms seeking to expand internationally — to improve or develop myriad policies, position-specific compliance training programs, third-party due diligence procedures, and internal controls tailored to the economic sanctions, export controls, customs, and ABC risks faced by his clients.

Relatedly, a substantial portion of John’s practice is devoted to counseling clients on international regulatory matters, including economic sanctions programs conducted by the Office of Foreign Assets Control (OFAC), export controls issues under the International Traffic in Arms Regulations (ITAR) and Export Administration

Regulations (EAR), ABC issues under the Foreign Corrupt Practices Act (FCPA), and import-related issues overseen by Customs & Border Protection (CBP). John’s experience includes conducting numerous internal investigations and defending corporate clients facing enforcement actions by the U.S. Department of Justice or other federal or state 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 ABC 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
19 March 2024 Legal News: International Trade Enforcement & Compliance

Five Compliance Checks Every Multinational Company Needs to Consider for … Customs Compliance

Now that Customs collects full electronic data on all imports, its ability to identify potential underpayment of tariffs and pursue other violations of Customs requirements is greatly enhanced.
19 March 2024 Manufacturing Industry Advisor

What Every Multinational Company Should Know About … Export Controls and Economic Sanctions Red Flags (Red Flags Series Part II)

As is true with anticorruption compliance, it is important that multinational companies identify, distribute, and educate personnel regarding export controls and economic sanctions red flags.
08 March 2024 Deals and Wins

Foley Represents Novacap in Strategic Partnership with INdigital

Foley & Lardner LLP served as legal advisor to Novacap, one of North America’s leading private equity firms, in its definitive agreement to acquire Communications Venture Corporation, Inc., doing business as INdigital.
06 March 2024 Manufacturing Industry Advisor

What Every Multinational Company Should Know About … Anticorruption Red Flags (Red Flags Series Part I)

Anticorruption efforts have been an enforcement priority of the U.S. government for the Foreign Corrupt Practices Act for several decades now, with other countries increasingly taking a more aggressive posture on anticorruption enforcement as well.
21 February 2024 Manufacturing Industry Advisor

What Every Multinational Company Needs to Know About … CBP’s Uyghur Forced Labor Prevention Act Detentions and Admissibility Reviews (Part III)

In this third and final UFLPA post, we provide guidance regarding steps that importers can take if they find that their goods have been detained by U.S. Customs and Border Protection for UFLPA concerns and now must go through a UFLPA admissibility review.
31 January 2024 Manufacturing Industry Advisor

What Every Multinational Company Needs to Know About … The Uyghur Forced Labor Prevention Act Due Diligence and Compliance (Part II)

In this post, we provide a detailed set of model UFLPA due diligence and risk-management strategies for importers at risk of UFLPA detentions.