2025 BEST PRACTICE AWARDS

Best Enforcement Program

The primary problems that occur with direct-to-consumer( D2C) shipping include age verification, enforcement, bypassing the three-tier system and differing laws from state-to-state, among others.

Despite this madness, the Vermont Department of Liquor and Lottery’ s Office of Compliance and Enforcement’ s( OCE) approach to regulating DTC alcohol shipments has reshaped enforcement strategy in the state. It’ s also drawn national attention for its innovation, effectiveness and potential for replication across jurisdictions.

Recognizing the growing risks posed by unregulated DTC shipments of alcohol beverages, OCE launched an innovative pilot compliance initiative targeting online shipments— both licensed and unlicensed— into Vermont. This enforcement strategy adopted lessons learned from the agency’ s earlier success in curbing illegal DTC tobacco sales and applied them in a more complex alcohol marketplace.

“ The enforcement program has really highlighted how critical it is to protect the community by testing and documenting how alcohol is being shipped online,” says Brandon King, deputy chief, Vermont Department of Liquor and Lottery.“ Through this program, we’ ve exposed some gaps that could have put minors at risk.”

The different elements that the compliance initiative had included:

• Digital Marketplace Surveillance: OCE investigators proactively monitored websites and e-commerce platforms to identify businesses— both in and out of state— marketing alcohol for delivery into Vermont.

• Controlled Purchases: A total of 116 controlled online purchases were conducted using a designated residential delivery address and secure payment systems. Deliv-

eries were monitored, documented and reviewed for legal compliance.

• Youth Access Testing: To assess risk to minors, select test purchases involved employed underage operatives, allowing OCE to determine whether sellers utilized robust age-verification protocols.

• Clear and Compelling Results: Of the 116 attempted online alcohol purchases, 40 packages were successfully delivered. Alarmingly, none were delivered in full compliance with Vermont law.

“ The compliance initiative gave us evidence to address a growing public safety concern not only in Vermont, but nationally,” King notes.“ It also positioned us to lead the national conversation around DTC compliance, which we have discussed at numerous conferences and events with stakeholders.”

Due to the success of the OCE’ s compliance initiative, the administration has been invited to present its findings and methods at a variety of national forums, including The National Liquor Law Enforcement Association( NLLEA) Annual Conference, The National Alcohol Beverage Control Association( NABCA) Legal Symposium and The National Conference of State Liquor Administrators( NCSLA).

Through these presentations, the OCE has shared enforcement insights, compliance data and practical tools with regulators and enforcement professionals from across the country. These efforts have advanced the national conversation around DTC alcohol regulation and helped shape emerging enforcement models in other states.

“ One of the biggest takeaways from this compliance initiative is seeing just how difficult it is to properly enforce online alcohol sales and shipping on a consistent basis,” says King.“ The digital marketplace changes daily and keeping pace requires resources, collaboration and creative strategies.”

Going forward, King says the OCE wants to conduct more of these compliance initiatives, but more importantly, conversations need to be had with stakeholders about what effective enforcement looks like in this industry.

20 StateWays • Fall 2025 www. stateways. com