Exiting the tobacco market is not an option for Circle 0.
This is not uncommon as many industries are facing high compliance failure costs—e.g., BSA/AML, Economic Sanctions.
You as the Chief Compliance Officer have been asked to evaluate the current state of tobacco sales compliance and formulate programmatic recommendations to improve compliance with tobacco sales regulations.
The Board of Directors and the CEO are very keen to learn your findings and recommendations in preparation for the FDA review of Circle 0 in Q4 (the fourth quarter).
It is important that you consider both upstream and downstream corporate functions that may be impacted by your analysis and recommendations.
Circle 0 FDA Tobacco Inspection Report Download Circle 0 FDA Tobacco Inspection Report
Please write a 3-5 page memo to Circle 0’s board of directors and CEO, answering the following questions:
What did you learn from the data analysis?
The FDA inspection results are publicly available but Circle 0 was caught off guard. What do you recommend to avoid this in the future?
What are you considering in your business/risk management tradeoff analysis?
Compliance culture problem?
An incentive problem?
Business and operational costs?
Potential root causes?
Are your recommendations practical?
What is the residual risk for your recommendations? Or are they perfect? Transparency is key.
Who else have you engaged in your analysis for input and alignment?
Do you anticipate pushback from other members of the CEO Leadership team during your presentation? If so, how are you preparing for it?