Recent corporate FCPA settlements with the SEC and DOJ show that foreign subsidiaries continue to be an area of anti-corruption risk for multinational companies. Even if a parent company has a strong compliance culture and accompanying program, failing to integrate that culture with its subsidiaries can lead to problems, as can failing to keep lines of communication open between the parent and its subsidiaries. In this second article in our three-part series on managing subsidiary risk, we look at how companies can make subsidiary employees partners in compliance. The first article in the series discussed how companies can set up their subsidiaries to minimize risk, and the third part will examine the internal controls a company should have in place to prevent corruption at its subsidiaries. See “How to Build a Compliant Culture and Stronger Company From the ‘Middle’ (Part One of Three)” (Apr. 1, 2015); Part Two (Apr. 15, 2015); Part Three (Apr. 29, 2015).