As discussed in our prior two alerts in this series, the expanded liability due to the Fraud Enforcement and Recovery Act (FERA) Amendments to the False Claims Act (FCA), a larger universe of and greater incentive for whistleblowers, and a new administration eager to expand FCA enforcement foreshadow a likely increase in trade-related FCA claims. In this final installment, we explore how recent changes to the landscape of international trade law create increased FCA exposure for importers and what actions companies can take to mitigate these risks.