1. Pour milk into medium bowl. Add dry pudding mix. Beat with wire whisk 2 min. or until well blended.
2. Line 8-inch round cake pan with plastic wrap. Arrange 14 of the cookies on bottom of prepared pan; spread 1 cup of the pudding mixture over cookies. Repeat layers of 14 cookies and remaining pudding mixture; cover with plastic wrap.
3. Refrigerate at least 24 hours. Uncover. Invert onto serving plate; remove plastic wrap. Frost with the whipped topping. Add 2 remaining cookies for the eyes and the carrot for the nose. Cut licorice into 6-inch length; add to face for the mouth. Store in refrigerator.

Yield: 10 servings