Dorthe Tolborg

“Difficult decisions should always be difficult to make.”

Jeroen: Dorthe Tolborg, thank you very much for taking the time to speak with Leaders in Finance ahead of the Leaders in Finance Compliance Event on the 18th of this month. I’m really glad you’ll be joining us as a keynote speaker, and I also appreciate you taking the time today for this short and engaging pre-event interview. To begin, could you please introduce yourself and tell us a little about your background?

Dorthe: I’m currently Chief Compliance Officer at Danske Bank, a role I’ve held for just over two years, which also makes me part of the executive leadership team. Before that, I spent nearly a decade as head of internal audit at Danske Bank, following a similar role in an insurance company. The first 20 years of my career were with the big four accounting firms.
So governance, control and risk are very much in my DNA. That’s what I’ve always been drawn to – understanding how organizations can be resilient and accountable. But what I value most in my current role is working across the bank to support what really matters: protecting our customers, safeguarding the bank, and ultimately contributing to the stability of society.

Jeroen: That’s an impressive amount of experience you bring to the table. What do you ultimately enjoy most about your current role?

Dorthe: I enjoy my role a lot. I’m very much a people person. I focus a lot on the interactions within my own team, but also on how we can work with the rest of the organization and the bank as a whole –because there are common goals we want to achieve. For example, ensuring compliance in a specific area can be challenging, so we need to be very strong in communicating with an enterprise mindset. I find that extremely exciting.
What I also enjoy is that we often need to team up to achieve results. Teaming up means working not only within our own group but also across the wider organization. That’s engaging, and it’s rewarding to see that we accomplish things together. That’s probably the aspect I would highlight most.
Of course, there are also the more routine tasks – regulations to follow and administrative work. But those are part of the bigger picture: if we set up the organization properly, foster a culture of teamwork, and collaborate across the bank, then even those tasks contribute to achieving what we need as an institution.

Jeroen: Does this mean you spend a significant amount of time engaging with the first line, management teams, and different business lines – not only to understand what’s happening, but also to shape and influence the compliance culture you want to see?

Dorthe: Yes, that’s right. First of all, we need a solid understanding of the business – the activities within the bank, how they operate, and what the strategic priorities are. Only with that insight can we make sure we’re supporting the business in a timely and effective way.
A major focus for us is ensuring that whatever is developed or implemented is compliant by design. That approach makes processes more efficient and prevents costly remediation later on. To get there, we need visibility of what’s happening and access to the right forums at the right time. One of the key levers for that access is being seen as a trusted advisor. And that’s not a status you’re handed – it’s something you earn. That’s where we’re putting a lot of emphasis.
Are we exactly where I want us to be? Not yet. But there are plenty of signs that our contribution is valued, and I see even more opportunities ahead. In my view, we can never engage with the business too much – continuous interaction is essential to building the strongest possible partnerships.

Jeroen: You mentioned that being compliant by design requires a deep awareness of how products work, how the business operates, and what is being offered to customers. Looking more broadly, what do you see as the biggest challenges facing chief compliance officers and compliance teams in financial services today?

Dorthe: I think there are quite a few, and I’ll also touch on them when we meet later in September. The whole geopolitical situation, as we see it, has a huge impact on our customers. It has a big impact on us as a bank as well. We need to do our utmost to understand what’s happening, assess the risks, and prepare as best we can to manage them when they materialize – and some of them inevitably will. The geopolitical situation is closely linked to sanctions, which continue to evolve. We need to make sure we understand the regulations, comply with the frequent changes, and at the same time help our customers navigate them. GDPR also remains a challenge. It’s a highly complex regulation, and there is still more work to be done. Financial crime is another key issue – everyone is facing risks there, so we need to stay on top of them. But equally important are conduct and the broader culture question. Just yesterday I was at a meeting with another chief compliance officer, and we discussed culture – specifically, how to truly understand the culture of the organizations we’re in, and how to identify pockets where it may not align with expectations. That is extremely difficult, and it’s a challenge we need to stay very conscious of: how can we identify those areas, act on them, and get back on track?

Jeroen: How do you view the technological developments that are shaping compliance, and what do you see as the main opportunities and challenges arising from them?

Dorthe: Generative AI is a real focus area for us – not only for the bank as a whole, but also within compliance. The bank is moving quickly to develop what will take us into the future, which is positive, but it also means we must understand the risks and ensure proper governance is in place. In compliance, we need to upskill to fully grasp those risks, and we’ve put a lot of effort into that. From the beginning, we insisted on being part of these developments so we wouldn’t be left playing catch-up. It’s also important to look at how, within Group Compliance, we can work more efficiently by using generative AI. We already have a few solutions in production, and more will follow, but we need to make choices – we can’t do everything at once. Yesterday I met with my extended leadership team for a session on generative AI. One of the frontrunners in this area gave a presentation and admitted, “Right now I’m shooting at everything that moves – but that can’t go on. We need to narrow our focus and concentrate on the bigger wins.”  She’s right: we need to narrow our focus and target the bigger wins. To sum up, our focus is twofold: understanding what the business wants to achieve with generative AI and ensuring that we are compliant by design, while also leveraging it to improve how we work internally.

Jeroen: If you could give one or two tips for people starting out in compliance in financial services, what would they be?

Dorthe: Whenever someone new joins my team – and we’re more than 500 people now – I make a point of meeting them. I always ask newcomers to stay curious: to really understand what’s going on, to ask questions, and to challenge how we do things. Long-timers can become blind to routine, so fresh perspectives help us do things differently and better.
Beyond that, we’re also working on shifting the compliance mindset. Instead of starting from “no, you can’t do that,” we try to begin with “that sounds interesting, but challenging – let’s discuss how we might move forward.” It’s not always black and white; the aim is to find solutions together. For some, that requires a bit of a mindset shift, but I’ve seen it generate real energy.
And just yesterday, a colleague here in Denmark put it nicely: “Difficult decisions should always be difficult to make.” In other words, let’s focus our attention where it really matters, and not get stuck on the smaller calls.

Jeroen: That’s very true, and it resonates strongly with me. Dorthe Tolborg, Chief Compliance Officer at Danske Bank, thank you for taking the time to share your insights. We greatly look forward to welcoming you at our event.

Dorthe: Thank you. I’m looking forward to joining the event as well.