PROCUREMENT WITH PURPOSE
Claribelle Rohde on Scaling Strategy, Risk, and Resilience at Banking Circle
Two years ago, when Claribelle Rohde joined Banking Circle, part of her mandate was to redefine and transform the bank’s procurement and outsourcing function in line with industry best practice. As the bank expands rapidly across multiple jurisdictions, it requires a resilient, future-ready operational model to support its fast-scaling global business. As Head of Procurement and Outsourcing, Claribelle is positioning procurement to become a strategic driver of value, resilience, and operational excellence, embedding it into the fabric of the bank, while continuing to navigate the complexities of regulation, digital transformation, and third-party risk.
In this exclusive interview, Claribelle shares her insights on managing supplier compliance across borders, designing future-ready operating models, and driving cross-functional alignment in the face of evolving requirements like the industrydefining DORA (Digital Operational Resilience Act) regulations, along with her vision of a scalable procurement function. She is embedding enhanced risk controls into core processes while setting the foundations for modern, adaptable platforms, shaping a procurement function that is structured yet agile, ambitious yet grounded. Whether you are a procurement leader navigating regulated sectors or simply looking to build smarter, more collaborative procurement functions, Claribelle’s journey offers valuable lessons in leadership, resilience, and intelligent growth.
Building Procurement from the Ground Up
You played a key role in building and supporting Banking Circle’s new approach to its central procurement function. What were the critical steps in defining your target operating model, and how did you approach establishing scalable governance?
When I joined Banking Circle, procurement was rooted in governance and compliance a function designed to meet regulatory demands. As the bank’s global footprint grew, I set out to evolve its purpose: moving beyond oversight to enable scale, resilience, and growth across multiple jurisdictions, while strengthening the foundations that were already in place. Banking Circle is headquartered in Luxembourg. When I joined, the bank’s network included branches in Denmark, Germany, and the UK. Since then, the scope of procurement has expanded significantly. Today, I provide central procurement support not only to the bank’s European branches, including new locations such as Poland but also to its subsidiaries in markets such as Liechtenstein, Singapore, and Australia, with additional geographies in the pipeline as we continue our global growth. We are shifting from an EU-centric operation to a global procurement organisation that supports scale, resilience, and growth worldwide.
In a fast-growing, regulated banking environment, this meant striking a careful balance between agility and control. The first step has been to shift perceptions of procurement –from a transactional or compliance-focused function to a strategic business partner that adds value across the organisation. We are working towards the bank’s core priorities and aligned our target operating model to support its strategic pillars. Procurement is increasingly expected to facilitate growth by enabling rapid expansion into new geographies and supporting third-party engagements to bring new products to market. This means continuing to build scalable processes and involving procurement early to avoid bottlenecks, while still ensuring commercial discipline and regulatory alignment. To support business stability, we are building governance frameworks that are aligned with regulatory expectations and apply a risk-based, proportionate approach. This includes supplier segmentation, clear approval thresholds, and embedded controls. These are co-designed with our Legal and Risk teams and focuses not only on meeting external requirements, but also on ensuring operational resilience from our third-party suppliers, particularly those supporting critical or crossborder services.
Profitability has been another key driver. We are focusing on creating commercial value through stronger contract negotiations and by challenging the business to rationalise spend where it makes pragmatic sense, while also improving procurement cycle times and reducing internal friction. Supporting the business efficiently requires balancing speed with rigour. Looking ahead, we are beginning to embed procurement more deeply into the bank’s broader enterprise system. This will allow us to gradually increase automation, enhance visibility, and drive more integration across functions. This journey will support our ambition to scale globally while strengthening control and enabling stronger, data-informed decision-making.
Regulatory Resilience under DORA
What was involvement in your third-party remediation efforts to meet DORA requirements, and how has this uplift shaped the bank’s broader operational resilience strategy?
Like many in the industry, DORA prompted us to rethink and strengthen our third-party risk and outsourcing frameworks so we stay firmly ahead of regulatory expectations. Our remediation efforts began with a group-wide gap assessment across third-party arrangements, with a particular focus on ICT and critical or important functions. We are committed to continuous improvement, regularly benchmarking our frameworks against evolving best practices and regulatory standards. We have re-baselined our outsourcing registers, reclassified our suppliers for greater consistency, and are actively negotiating with critical partners to strengthen contractual terms with standardised clauses on access, audit rights, termination, and subcontractor transparency. It is an ongoing process, some suppliers were more DORA-ready than others and we are continuing to build on this momentum to ensure clarity and resilience across the group.
Our risk assessments were updated to reflect DORA’s emphasis on concentration risk, chain outsourcing, and ICT-specific threats. We also clarified the roles and responsibilities of service owners, risk teams, and procurement to ensure accountability across the full third-party lifecycle. This uplift is already shifting how outsourcing is perceived, from a transactional necessity to a core pillar of our resilience planning. We have embedded third-party risk considerations much earlier in both procurement and product development processes, with growing emphasis on interdependency mapping and scenario planning. The programme is also deepening cross-functional collaboration between risk, legal, and business teams, positioning procurement not just as a policy executor, but as a strategic enabler of resilience. In many ways, DORA is accelerating our transition from decentralised oversight to a more integrated, group-wide approach to risk and operational continuity.
Global Oversight of Third-Party Relationships
With oversight across multiple jurisdictions, how do you manage supplier consistency and compliance across Banking Circle’s headquarters, branches, and subsidiaries?
As the bank expands into new jurisdictions, one of the new and complex challenges we are tackling is how to manage third-party risk consistently across the group, without creating unnecessary complexity for local teams. This work is very much in progress and is shaped collaboratively with our Strategic Expansions, Risk, Legal, Finance, Tax, Governance and other functional departments and management teams within our sub-entities. My focus in the next few months is establishing a strong foundation at group level, defining clear procedures that balances risk and regulatory defensibility, a unified supplier categorisation model, standardised due diligence processes and a standardised internal service catalogue to enable our intragroup expansions, while working closely with each entity to adapt these to their specific regulatory environments. It is an ongoing balancing act between ensuring consistency and allowing for local flexibility, and while it’s not always perfect, we are learning and continuously improving with each new market we enter.
To support this, we have set up a third-party management working group that includes legal, risk, business stakeholders, and service owners. This forum enables coordinated yet pragmatic decisionmaking, particularly for cross-border or higher-risk engagements and ensures procurement acts as a connector to bridge silos.
While this framework is still maturing, it is already helping us to manage third-party relationships in a way that supports both regulatory compliance and practical business needs, while maintaining the agility needed to support the bank’s continued growth across multiple jurisdictions.
Embedding Risk Controls into Procurement
How have you designed procurement processes to align with regulatory risk requirements without compromising on speed or value?
Designing procurement processes that meet regulatory risk requirements without slowing the business has been one of our biggest ongoing challenges and it is a delicate balancing act. It often feels like sprinting on a tightrope, moving quickly and adapting to changes from the regulatory landscape or pace of business acceleration, while making sure we stay securely harnessed and anchored to maintain stability and control. Our approach is to embed risk requirements directly into procurement workflows – weaving regulatory expectations into how we source, assess, and contract with suppliers, so that risk is addressed by design rather than as a late-stage hurdle. We have continued to integrate these requirements into our processes, ensuring compliance is seamlessly built into the way we work.
We are shaping a tiered, risk-based model that scales due diligence, approvals, and oversight depending on the risk and criticality of the supplier and the service they are providing. This work is highly collaborative –Legal, Risk, and Governance and business inputs are essential to co-developing contract templates, risk assessments and approval workflows so that we are not re-inventing the wheel for every engagement and can move faster while staying compliant.
Early procurement engagement remains a key focus. By engaging procurement before business decisions are locked in, we can shift risk assessment upstream, add strategic input, and reduce downstream delays.
Equally important is creating awareness across the business. Over the past year, we’ve introduced monthly ‘How to Buy in Banking Circle’ training for all new joiners to reinforce why engaging procurement early matters, because, anyone in the company can initiate a purchase. As DORA raises the regulatory bar, we’ve also organised internal roadshows with service owners and held supplier-facing sessions to align expectations and drive proactive ownership of risk. These efforts make risk management a shared responsibility across the organisation rather than the remit of a single team.
These training sessions have been invaluable for me personally, they’re a chance to meet new colleagues as the company rapidly grows to more than 700 employees across Europe, Asia, and Australia, expanding through new branches and subsidiaries. These help me stay close to emerging roles, new geographies, and upcoming products.
Our goal is to make the right way the easy way, enabling the business to move fast while knowing that compliance and control are already built into the process.
Strategic Partnerships as Value Drivers
How do you identify and nurture long-term strategic partnerships within your supplier base, and what role do these relationships play in driving Banking Circle’s growth and innovation?
We have worked to shift purely transactional procurement toward building longer-term strategic partnerships, especially with suppliers that underpin critical parts of our infrastructure. A good example is the recent renewal of one of our key IT partners, an arrangement that supports the very bedrock of the bank. Instead of treating it as a routine negotiation focused solely on cost, we approached it as a chance to reposition ourselves as a customer of choice and to explore how the relationship could evolve with our global ambitions.
With our growth and expanding global footprint, we are recognising the importance of creating partnerships that go beyond just driving costs down and we are starting to actively think where building such partnerships matters and drives value both for us and our suppliers. In a market where negotiation often defaults to price, we are starting to take a more open and transparent approach with select suppliers, sharing our roadmap and inviting them to partner with us on our global ambitions. This more open and transparent approach has already helped unlock additional investment, secure funding commitments, and even identify potential new sales channels with one of our key partners and we will be looking toward our other key suppliers to start partnering with us in the same way. We know that this is just the beginning and it is not a one size fits all. We are continuing to identify other key strategic suppliers where we can cultivate a partnership approach, not only based on what they deliver today, but also on how we can innovate and scale together. It is not easy; we are not always the biggest fish in the pond for some of our large suppliers. But with the growth we have shown, some key partners are beginning to see our trajectory and are genuinely excited to grow alongside us and invest in our potential. The aim is to go beyond the contract, to build true partnerships that strengthen resilience, support our global growth, and create long-term value for the bank.
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My vision is simple: a business stakeholder can upload a proposal or product description, and from there, everything flows – no unnecessary forms or back-and-forth. Instead, automated, intelligent workflows handle the routine, while human touchpoints focus where they matter most: building trust, forging relationships, making informed, risk-based, and proportional decisions, supported by the right data at the right time. That is the future we are building toward, and there is a long way to go but to quote Lao Tzu – “the journey of a thousand miles begins with a single step.” The steps we are taking now are what will make that vision possible.
Cross-Functional Collaboration
What has been key to ensuring successful collaboration between procurement and internal stakeholders like risk, legal and the wider business?
At the heart of any successful collaboration is trust and that takes time to build. When I joined, procurement’s role was limited and not well known, especially to new joiners. It was often seen as an administrative hurdle: extra forms, unclear requirements, and processes that didn’t feel connected to the business. This lack of visibility meant many employees did not fully understand procurement’s processes or how the department could support them. Some requirements, particularly those driven by regulation, weren’t well understood and could seem unnecessary, though we knew they were essential to demonstrate control and protect the bank. To shift that perception, we’ve focused on being accessible and pragmatic: showing up as partners, listening first, understanding pain points, and finding places where we can simplify and deliver quick wins. Over time, even initially reluctant stakeholders have begun to see that procurement isn’t just bureaucracy. The questions we ask challenge the business to make better decisions, and documentation becomes a natural outcome of those decisions rather than a burden. Alongside this cultural shift, we have promoted procurement’s role internally, improved communication across departments, and helped colleagues navigate the right processes. Regulatory initiatives such as DORA have also underscored the importance of structured procurement and third-party management, further strengthening the function’s visibility and integration.
A great example is how we collaboratively worked with Risk and Legal to develop a new approach to third-party classification under DORA. Instead of working in isolation, we ran joint design sessions where each team brought its perspective. There were iterations, debates, and even some false starts, but we ended with a much stronger, clearer model and more importantly, shared ownership. We now have allies who advocate for proactive engagement with Procurement, but the journey is ongoing; there will always be new colleagues and some sceptics to win over. Collaboration thrives when teams have the freedom to experiment, and when they feel safe enough to try, fail, pivot, and try again. It is not about getting everything perfect on the first attempt, it is about creating space to learn and evolve together. Ultimately, it’s about shared accountability, psychological safety, and making compliance feel like basic hygiene so we can focus on the exciting part, creating real value in our contracts, from competitive pricing and commercial protection to access to supplier expertise and innovation and where procurement is recognised not as a gatekeeper, but as a connector and business enabler.
Navigating Multijurisdictional Compliance
What challenges have you faced in aligning third-party risk management across varying regulatory landscapes, and how have you addressed them?
One of the biggest challenges we are navigating right now is how to align third-party risk management across multiple regulatory landscapes. While frameworks like DORA, EBA, CSSF, FMA, MAS, and APRA share core principles, each brings its own nuances, interpretations, and expectations. Many of these rules are still new and theoretical, and their application can differ from one jurisdiction to another. To address this complexity, we combine insights from external advisors with strong internal efforts, attending targeted trainings and bringing in local employees with deep regulatory expertise to ensure our approach is both compliant and practical across all markets we operate in. The key tension we manage daily is finding the right balance, avoiding over-engineered controls that introduce unnecessary business friction, while also preventing under-standardisation that can weaken group-level oversight. That balance is not always easy to strike.
We are focusing on adopting a risk-based and proportional approach, establishing a group-wide baseline that reflects our risk appetite and overarching regulatory obligations, while still allowing for local overlays where needed. Rather than taking a purely rules-based stance, we aim to interpret requirements through their intended purpose. Are we managing concentration risk? Enabling resilience? Protecting customer data? Keeping this lens helps us avoid a tick-box mentality and stay focused on outcomes that matter. We have to pick a point on the spectrum and keep fine-tuning it, it is an ongoing calibration so we can shift quickly when things change. Continuous close collaboration with legal and risk teams across jurisdictions has also been critical. We challenge interpretations together, align on what is defensible and practical, and make sure our group standards do not conflict across regions. This joint effort prevents siloed decision-making and keeps the framework coherent but flexible.
Managing compliance across multiple jurisdictions is not a project with an end date –it is a continuous process of alignment, proportionality, and responsiveness, ensuring that third-party risk is managed cohesively across the group while still enabling the business to grow.
Evolving the Procurement Function for Scale
As the bank scales, how are you future-proofing procurement to meet growing business demands?
Future-proofing procurement is about more than just adding headcount or refreshing templates, it is about designing a function that can scale intelligently and sustainably as the business grows, complexity, and geography. I will admit I am still figuring out what this really looks like in practice. AI is everywhere in our personal lives now, and I am learning from peers in the industry who are future proofing their teams to embed AI, exploring how it might help us scale without losing the judgment and control we need.
Right now, our focus is on building repeatable, proportionate, and automation-ready processes. Whether we are onboarding a low-risk vendor or negotiating a strategic partnership, the aim is to avoid reinventing the wheel each time. We are also embedding procurement earlier into business planning cycles, allowing us to anticipate needs before they arise, rather than responding reactively. Our digital transformation efforts are a key part of this journey. Through our integrated enterprise transformation programme, we are connecting procurement with finance, risk, legal and governance within one shared platform. This will give us the structure and visibility required to manage third-party engagements consistently, while still maintaining agility to keep pace with business demands.
We are also starting to use AI as a practical productivity tool, for example, to make our communications clearer, assist with supplier due diligence, and help summarise key points from complex regulations across multiple jurisdictions. It is not about relying on AI to do the work for us, but about using it to augment our teams and free capacity for higher-value analysis and decisionmaking.
Equally important is the people aspect. We are strengthening internal guidance, rolling out training for both the procurement team and the wider business, and shifting the perception of procurement from process enforcer to value enabler. As our remit expands from local to group-level, we are also enhancing cross-jurisdictional collaboration to ensure global consistency while respecting local regulatory nuances.
Future-proofing procurement means building a function that is scalable, adaptable, and aligned with the bank’s strategic goals, so we can support growth with confidence, no matter how fast or far the business evolves.
Leadership Lessons in Regulated Environments
What advice would you offer to other procurement leaders establishing functions in fast-paced, highly regulated financial services environments?
When I took on the role as Head of Procurement and Outsourcing, my CFO said something that really stuck with me: “You need to be prepared to take, and accept, risks.” At the time, that felt counterintuitive. My entire procurement career had focused on minimising risk, negotiating service credits, building in exit clauses, and limiting liabilities. So the idea of embracing risk, even to a degree, was a significant mindset shift. In highly regulated environments, the goal is to make informed decisions based on the best available data and to be comfortable with the risks you choose to accept, balancing structure with sound judgment.
I have learned that in fast-paced, highly regulated environments, the goal is not to eliminate all risk, it is to make informed decisions based on the best available data and to be comfortable with the risks you choose to accept. That has been one of the biggest leadership lessons for me.
I have also come to appreciate the power of prioritisation. In an environment filled with competing requirements and tight deadlines, I regularly ask myself and my team: “Does this really matter?” Not every issue is critical, and learning where to focus your energy is essential to building something sustainable.
If I had one piece of advice for other procurement leaders, it would be this: get comfortable with ambiguity, focus on what truly moves the needle, and be willing to evolve your mindset. In regulated environments, it is the ability to balance structure with judgment that makes the difference.
Banking Circle S.A. is fully licensed as a bank in Luxembourg and is committed to building a local clearing network for all major currencies, to deliver fast, lowcost payments, enabling payments companies and banks of any scale to seize opportunities in the new economy. It provides a suite of unique and award-winning banking solutions, including multi-currency banking accounts and Virtual IBANs, bank connections for local clearing and cross-border payments, all underpinned by market-leading compliance and security.
Claribelle Rohde Head of Procurement and Outsourcing