Tom C. Vincent
Partner | Corporate
tom.vincent@pierferd.com
+1.918.398.1831 cell
+1.202.571.7975 office
Washington, D.C.
PDF – vCard
About
Tom Vincent is a Partner at Pierson Ferdinand LLP, a Certified Information Systems Security Professional (CISSP), Certified Regulatory Compliance Manager (CRCM), and Certified Information Privacy Professional (CIPP/US). Tom approaches cybersecurity and privacy not just as technical issues but as questions of identity, autonomy, and trust. With over twenty years in banking and regulatory leadership—including roles as Chief Compliance Officer, BSA/AML Compliance Officer, HIPAA Compliance Officer, and Corporate Secretary—he brings an insider’s perspective on how regulation, risk, and reputation converge. Today, Tom counsels financial institutions, technology startups, and healthcare organizations on cybersecurity, data privacy, and corporate governance, helping them move from compliance to accountability while preserving their corporate identity.
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As an Adjunct Professor of Cybersecurity Law and Policy at The University of Tulsa College of Law and a mentor to privacy practitioners, Tom teaches how digital governance intersects with human ethics. He guides lawyers, compliance officers, and privacy and security professionals in developing careers rooted in integrity, helping them navigate complex intersections of law, technology, and inclusion with clarity and purpose.
Practices
Banking and Financial Services
Broker-Dealer Regulation
FinTech and Blockchain
Healthcare
Information Security
Privacy and Data Protection
Regulatory Law & Government Contracts
Securities
Technology
Admissions
Oklahoma
District of Columbia
Education
Washington and Lee University School of Law, J.D.
Southern Methodist University, B.S.
Memberships and Affiliations
Oklahoma Bar Association
Tulsa County Bar Association
American Bar Association
International Association of Privacy Professionals
Recognition
Best Lawyers, 2024-2026, FinTech Practice and Privacy and Data Security Law
Oklahoma Bar Association, 2023, Ada Lois Sipuel Fisher Diversity Award
Law Firm Experience
Gable & Gotwals, A Professional Corporation
Corporate and Faculty Experience
Adjunct Professor, Cyber Law and Policy, The University of Tulsa College of Law
Chief Compliance Officer/Anti-Money Laundering (AML/BSA) Officer/HIPAA Compliance Officer, The F&M Bank and Trust Company
Chief Compliance Officer and Corporate Secretary, Cavanal Hill Investment Management
Chief Compliance Officer, BOSC, Inc. (now BOK Financial Securities, Inc.)
Manager, Corporate Governance and Wealth Management Compliance, BOKF, N.A.
Non-Profit Service
Past Advisory Board Member, Oklahomans for Equality
Past Board member, Tulsa Zoo
Past Board member, Riverfield Country Day School Board of Trustees
Representative Matters and Experience
Privacy, Cybersecurity, Data Security, and Artificial Intelligence
Designed and implemented regulatory programs—including website disclosures, policies, procedures, training, and risk assessments—to meet FTC, FERPA, GLBA, GDPR, CMMC, and other state, federal, and international requirements.
Developed HIPAA compliance programs for healthcare clients, including policies, procedures, risk assessments, and entity-designation analyses for a healthcare mobile application, healthcare clinic, and university, covering covered entity, hybrid entity, and business associate designations.
Assessed GDPR and UK GDPR requirements for a U.S. energy company’s overseas acquisition.
Guided an international insurance carrier as outside privacy and cybersecurity counsel, including on policy and procedure development, vendor management, and engagement of private investigators.
Developed a CMMC compliance plan for a Department of Defense subcontractor, incident response plans for financial institutions and professional services firms, and Transportation Security Administration-required security measures for critical infrastructure.
Oversaw engagement of security firms for penetration testing and other security assessments, with request-for-proposal management and engagement agreement negotiation.
Directed insurance-approved breach response matters for privacy and security incidents across multiple states, territories, and countries, including reporting analysis, customer communications, agency communications, and insurance policy review for coverage sufficiency.• Drafted policies and developed controls for AI usage by clients and their vendors to ensure compliance with applicable laws and regulations, and provided training on ethical AI usage.
Developed an AI operational risk mitigation program, including governance structure, risk management framework, policies, and procedures for the development, implementation, use, and validation of AI systems.
FinTech, Financial Services, and BSA/AML
Negotiated FinTech agreement execution and termination, incorporated customer disclosures, and responded to banking agency compliance inquiries.
Analyzed cryptocurrency-secured lending and financing arrangements for consumer, vendor, finder, crowdfunding, and other financial services compliance issues.
Counseled financial institutions on BSA/AML reporting, including CTRs, SARs, and OFAC disclosures.
Addressed anti-money laundering, suspicious activity, OFAC reporting, and related financial-crime controls for an international insurance carrier.
Contracts, Third Party Risk, and Professional Services
Drafted client agreements, website documentation, and internal onboarding procedures for accounting and technology consulting firms.
Coordinated contract administration and third party risk management.
Marketing, Content Review, and Consumer Promotions
Reviewed advertising, social media, website, sweepstakes, and electronic transaction content under FTC, TCPA, and other applicable requirements.
Served as compliance counsel to a national multimedia company providing online memberships and sweepstakes giveaways.
Nonprofit Governance
Reviewed websites, bylaws, policies and procedures, and contracts for nonprofit entities regarding privacy, security, and corporate governance.
Selected Presentations and Podcasts
Co-Host, Aligned By Design: CISO X Legal (Podcast – Alias Cybersecurity)
“Artificial Intelligence and Fiduciary Obligations: Key Risk Considerations” (Tulsa County Bar Association), May 29, 2026
“Intellectual Property: Patenting and Trademarking” (speaking on website requirements, privacy policies, terms of use, and issues in utilizing artificial intelligence) (LAEDA, Inc.), May 28, 2026
“I Think, Therefore I Am (The Attorney): Preserving Autonomy Through the Ethical Use of Generative AI” (Lawline), December 10, 2025
“The Ethics of Inclusion: Developing the Words, Actions, and Achievements to Change Yourself and Your Practice (2025 Update)” (Lawline), September 22, 2025
“Authority and Accountability in Vendor Relationships: Setting Expectations, Avoiding Surprises, and Getting Your Stuff Back” (SECCON 2025 -Alias Cybersecurity), September 12, 2025
“Proactively Managing Vendor Relationships: Setting Expectations, Avoiding Surprises, and Getting Your Stuff Back” (Lawline), February 22, 2023
“What Now? Post-Breach Cybersecurity Issues: Addressing the Obvious and the Hidden, Not-Initially-Visible, and Otherwise Neglected Causes and Consequences of a Data Breach” (SouthWest Benefits Association), November 8, 2022
“Beyond Attorney-Client Privilege: Reconciling Traditional Attorney Issues and an In-House Environment” (Association of Corporate Counsel), September 16, 2022
“IT/IT Security, and Legal; Building Mutually Beneficial Relationships” (ISSA), November 8, 2021
“Cool to be Kind: The Expectation of Positivity and the Need to Belong” (DisruptHR Tulsa), October 20, 2021
“Cybersecurity! Why All the Cool Kids Are Doing It” (with Trent Shores, Oklahoma Association of Municipal Attorneys), September 9, 2021
“Avoiding Unintentional Exclusivity: Why the Language We Use Matters” (National Conference of Bar Foundations), July 31, 2021
“We’ve Been Hacked! What Do We Do Now?” (ISSA CyberSecurity Roundtable), January 26, 2021
“Embrace Your Blur: Using Your Authentic Self to Create Your Career Brand Narrative” (Black Wall Street Chamber of Commerce), November 12, 2020
“Courageous Conversations: Beyond the Hashtags” (Mosaic & Luxa Enterprises), August 25, 2020
“Life Preservers and Safety Nets: Returning to Work and Staying Afloat in COVID-19’s Wake” (Tulsa Area Human Resources Association’s Learning Lab), May 28, 2020
“Oh, What a Tangled Web(site) We Weave” (GableGotwals and Stinnett & Associates Cyber Webinar), May 13, 2020
“It’s not what you do, it’s why you do it: Ownership, Obligation, and Information Security” (Workforce Forensics Podcast), April 30, 2020
“Unexpected Legal Ethics Work-at-Home Webinar” (Avansic Work at Home Webinars), April 15, 2020
“Courageous Conversations Year End Celebration: 50 Shades of Courage” (LUXA 2nd Annual Year End Celebration), December 18, 2019
“Best Practices of Employee On-Boarding/Off-Boarding” (Tulsa Area Human Resources Association Employment Law & Practices Seminar), November 7, 2019
“To Secure and Protect: Fulfilling the Expectations of Clients (and Others) in Commercial Real Estate and Fiduciary Transactions” (Tulsa Title and Probate Lawyers Association), June 13, 2019
Selected Publications
Client Alert: When Influence Meets Compliance: FTC Endorsements, Privacy Policies, and Website Tracking Risk, June 16, 2026
Client Alert: Opening a Cryptocurrency Account: Security, Structure, and Consequences, June 4, 2026
Client Alert: Artificial Intelligence and Fiduciary Obligations (Part 1) — Key Risk Considerations, May 11, 2026
Client Alert: FinCEN’s AML and Stablecoin NPRMs Could Reshape Competition Between Banks and Non-Banks, May 4, 2026
Client Alert: Getting the Right Information and Protecting It the Right Way, Part 1: Website Data Practices and the Privacy–Terms Nexus, April 29, 2026
Client Alert: Reducing Cybersecurity Risks in Real Estate Transactions, October 21, 2025
Client Alert: No Company Too Small: Safeguarding Privacy and Cybersecurity in Renewable Energy, August 12, 2025
“A Need for New Armor: Tribal Entities Under Cyberattack” (with Emma Kincade and Trent Shores), GableGotwals Cybersecurity and Data Privacy Alert, October 21, 2021
“Chapter 14: Energy Cybersecurity Law – A Survey” (with Susan Lindberg and Trent Shores), Energy Law and Transactions (Matthew Bender), October 2021
“This Is Your Lucky Day” (Gavel to Gavel, The Journal Record), January 29, 2020
“Breaches and Attorney-Client Privilege” (Gavel to Gavel, The Journal Record), September 18, 2019