Restricted party lists (RPLs), which specify the individuals and other parties a company cannot do business with, are powerful tools in managing anti-corruption risk, but a recent court case called into question whether they can create risk as well. The Seventh Circuit Court of Appeals determined that Zimmer Biomet, one of the only companies to enter into two separate DPAs for FCPA violations, had not defamed a former employee by including him on an RPL. In a guest article, Jonathan Rusch, principal of DTG Risk & Compliance LLC, takes a close look at the Seventh Circuit’s holding and offers advice on how companies can avoid defamation liability when putting together an RPL. See “After Two Extensions of Its DPA, Zimmer Biomet Settles Further FCPA Charges for $30M” (Feb. 1, 2017).