Admissions
- Washington, DC
- California (inactive)
- Washington State (inactive)
- US Supreme Court and various federal courts
Education
- Columbia Law School, JD, 1993
- Managing Editor, Journal of Chinese Law
- Certificate in International Law, Columbia University Parker School
- Harlan Fiske Stone Scholar, 1992 and 1993
- Jessup International Law Moot Court Competition, 1991-92 and 1992-93
- Grants awarded: Human Rights Internship and Student-Funded Fellowship.
- Stanford University, AB in History with Honors, 1990
Overview
Having started his career as a Treasury Honors Attorney in the legal office for the Office of Foreign Assets Control (OFAC), Perry has handled hundreds of economic sanctions for numerous clients over the past 30 years. Perry has helped clients with an array of sanctions projects, including civil penalty proceedings, compliance, counseling, delisting, expert testimony, internal investigations, interpretative rulings, licensing, litigation, securities disclosure, and supporting corporate counsel with sanctions-related due diligence and drafting and negotiating sanctions-related provisions of contracts and deal documents.
Perry has assisted numerous clients over three decades with questions about national security review of international investments by the Committee on Foreign Investment in the United States (CFIUS) under the Exon-Florio Amendment to the Defense Production Act of 1950 (DPA), the Foreign Investment and National Security Act (FINSA), and the Foreign Investment Risk Review Modernization Act (FIRRMA). Perry has guided clients through numerous CFIUS “notice” and “declaration” projects, working on deals from start-ups seeking seed capital to major multinational corporate deals. He routinely advises both US companies and foreign investors on questions about whether to submit their deals for CFIUS review.
Perry has also managed other significant international projects before federal courts, federal regulators, and international tribunals. His projects have included cross-border litigation and arbitration, internal investigations, international negotiations, management of legal and political risks, expropriation claims under political-risk-insurance policies, regulatory proceedings, and dispute settlement under international trade agreements. His clients have included national governments, international organizations, individuals and small businesses, and leading businesses in agriculture, banking and finance, energy, manufacturing, real estate, services, and technology.
Representative Experience
- Successfully led the delisting of two subsidiaries of a multinational company, which had been sanctioned based on allegations of corrupt practices.
- Obtained numerous OFAC licenses and interpretative rulings, including authorization to unblock blocked funds, maintain property, exit investments in Russia, wind down business operations, collect unpaid debts, participate in international arbitrations, and organize people-to-people travel.
- Testified as an expert on OFAC sanctions in three recent major international arbitrations.
- Sitting as an arbitrator in an investor-state arbitration under a bilateral investment treaty (BIT) administered by the Permanent Court of Arbitration (PAC) in The Hague.
- Won challenges against both Indonesian restrictions on trade in automobiles and US antidumping duties on Korean steel under the World Trade Organization (WTO) procedures for resolving intergovernmental trade disputes.
- Secured dismissal of a federal class action alleging that OPEC violated US antitrust laws, affirmance by the Eleventh Circuit, and denial of certiorari.
- Prosecuted claims successfully under political-risk-insurance (PRI) policies for the expropriation of investments in Argentina and India, including the first “lender-side” claim paid by the Overseas Private Investment Corporation (OPIC), the second largest expropriation claim paid by OPIC, and a multimillion-dollar arbitral award.
- Negotiated a commercial and regulatory solution when the innocent buyer of Iraqi crude oil learned that the oil had been exported from Iraq in violation of the terms of the United Nations Oil for Food program.
- Wrote amicus briefs to the DC Circuit for the Mexican Government in cases about the constitutionality and implementation of certain provisions of the North American Free Trade Agreement (NAFTA).
- Worked pro bono for one month in Arusha, Tanzania at the International Criminal Tribunal for Rwanda, assisting the prosecution team with the trial of four accused architects of the Rwandan genocide. Regularly assist pro bono a major environmental NGO on its OFAC compliance.
Practice Focus
- Economic Sanctions (OFAC), including sanctions against Cuba, Iran, Russia, and Venezuela
- National security review of foreign investment in the United States (CFIUS)
- International trade law
- International dispute resolution, including investor-state dispute settlement (ISDS) under bilateral investment treaties (BITs)
Professional Affiliations/Recognition & Awards
- Ranked in Chambers Global for Economic Sanctions
- Ranked in Chambers USA for Economic Sanctions
- Ranked in Legal 500, Washington DC Elite for International Litigation
- American Society of International Law
- Executive Council, 2018-2021
- Chair, Committee on Interest Groups, 2019-21 Member, 2018-19
- Co-chair, Dispute Resolution Interest Group, 2015-18
- Co-chair, 100 Ways in 100 Days Task Force, 2017
- Co-chair, Practitioners’ Forum, 2017
- Co-chair, Research Forum, 2016
- Chair, David M. Caron Prize Committee, 2024
- Rapporteur on Economic Sanctions for Lviv Summit, 2023
- Member, Scholarship Awards Committee, 2016
- Member, Membership Committee, 2021-24
- Patron, 2021 – Present
- Faculty, Asia-Pacific Economic Cooperation Workshop on International Investment Agreements, Singapore and Washington DC, 2008
- Course Advisor, Course on Foreign Investment Agreements and Investor-State Dispute Settlement, International Law Institute, 2007
- Fellow, Salzburg Seminar on International Economic Institutions, Austria, 2002
- Term Member, Council on Foreign Relations, 1998 – 2003
- Research Fellow, Fair Trade Center, Tokyo, Japan, 1997-98
- Drafted U.S.-Hong Kong Policy Act of 1992, 22 U.S.C. § 5701
Publications
- Initial Thoughts on the IEEPA Tariff Rulings, Guest Post, International Economic Law and Policy Blog, May 2025
- What Does It Mean to be ‘Pro-ISDS’?, Pro-Arbitration Revisited: A Tribute to Professor George Bermann (Elora Farias, et al., eds.), 2023
- Investor-State Arbitrators’ Duties to Non-Parties, Duke Journal of Comparative & International Law, 2021
- Sanctions and the Blurred Boundaries of International Economic Law, Missouri Law Review, 2018
- Salini’s Nature: Arbitrators’ Duty of Jurisdictional Policing, Journal of Law and Practice of International Courts and Tribunals, 2018
- International Law: 100 Ways It Shapes Our Lives, American Society of International Law, 2018 (co-editor)
- Jurisdiction, Guide to Trade and Investment in a Globalized World (Patrick McCrory, et al., eds.), 2018
- Introduction – The Value(s) of International Dispute Resolution, Proceedings of the Annual Meeting of the American Society of International Law, 2017
- Microinvestment Disputes, Small and Medium-Sized Enterprises in International Economic Law (Thilo Rensmann, ed.), 2017
- Special Issue: International Arbitration in Africa, Transnational Dispute Management, 2016 (co-editor)
- The International Law of Game of Thrones, Alabama Law Review Online, 2015
- Homage to Filártiga, The Review of Litigation, 2014
- International Adjudication of Land Disputes: For Development and Transnationalism, The Law and Development Review, 2014
- Microinvestment Disputes, Vanderbilt Journal of Transnational Law,2012
- Lemkins Situation: Toward a Rhetorical Understanding of “Genocide”, Brooklyn Law Review, 2012
- The Politics of Divestment, The Politics of International Economic Law(Tomer Broude, et al., eds.), 2011
- Darfur, Divestment, and Dialogue, University of Pennsylvania Journal of International Law, 2009
- The Ponderosa Claim: OPIC Concludes that Argentina Violated International Law, Transnational Dispute Management, 2005
- Congress Turns to Capital Markets to Support Sanctions, International Financial Law Review, 2001 (co-author)
Speaking
- Commentator, International Law in Domestic Courts Workshop, Fordham Law School, 2026
- Commentator, International Law in Domestic Courts Workshop, George Washington University Law School, 2025
- Moderator, International Perspectives on Sanctions Law, University of Michigan School of Law, 2025
- Panelist, Invoking IEEPA for Tariff Implementation, 2025
- Commentator, International Law in Domestic Courts Workshop, University of Chicago Law School, 2024
- OFAC Licensing, American Conference Institute webinar, 2024
- Rapporteur, The Role of Sanctions in Moderating Russian Federation Behavior, Stand Tall for the Rule of Law Summit, 2023
- Trade and Investment, International Law Institute, 2023
- Due Process & Economic Sanctions, Wake Forest University School of Law, 2022
- Moderator, Roundtable on Economic Sanctions During the Ukraine War: A Practitioner’s Perspective, Texas A&M University School of Law, 2022
- Smart Sanctions, Harvard University, 2022
- Russia Sanctions: Implications for China, Renmin University webinar, 2022
- Russia Sanctions: Implications for Italy and Europe, International Chamber of Commerce webinar, 2022
- US Sanctions Policy during the Ukraine War, Foreign Service Institute, 2022
- Trade and Investment, Foreign Service Institute, 2022
- Biden’s Emerging Trade Policy, 2021
- ICSID Jurisdiction, International Law Institute, 2020
- Human Rights and Economic Sanctions, American Society of International Law, 2020
- Sanctions Trends, Lewis & Clark Law School, 2020
- Moderator, Helms-Burton Act Roundtable, University of Miami School of Law, 2020
- Moderator, A First Look at Helms-Burton Act Litigation, American Society of International Law, 2019
- CFIUS Introduction and Trends, International Law Institute, 2019
- US Sanctions: Implications for Korea, Korean International Trade Association, 2019
- Identifying Potential Defenses in Investor-State Arbitration, International Law Institute, 2019
- US Sanctions: Implications for BRIC Countries, Eurasia Center, 2019
- Regulatory Hot Topics in US-China Business: CFIUS, Sanctions, and Export Controls, Columbia Law School, 2019
- US Sanctions and Export Controls: Implications for China, Beijing International Arbitration Center, 2019
- CFIUS Overview, Trends & Recent Changes, Beijing International Arbitration Center, 2019
- Investor-State Arbitrators’ Duties to Non-Parties, Washington University School of Law and American University, 2017
- Investment Arbitration, International Law Institute, 2017
- Moderator, The Value(s) of International Dispute Resolution, American Society of International Law Annual Meeting, 2017
- Conference Co-Organizer, Works-in-Progress Conference on International Dispute Resolution, University of Missouri, 2017
- Conference Co-Chair and Discussant, Jurisdiction in International Law, University of Washington School of Law, 2016
- Workshop Co-Convener, Yale Law School, 2016
- The Blurred Boundaries of Economic Sanctions, Georgetown University Law Center, 2016
- A Question of Independence: Examining the Case for Replacing Investor-State Arbitration with an Investment Court, University of Bedfordshire, 2016
- Conference Co-Organizer, The Future of International Arbitration in Africa, Penn State International Arbitration Day, 2016, including presentations on Transnational Governance: The Zimbabwe Farm Cases and Investor-State Arbitration in Sub-Saharan Africa
- Moderator, Challenges and Recusals of Judges and Arbitrators in International Courts and Tribunals (Book Launch), International Centre for Settlement of Investment Disputes, 2015
- Justice and Investment Arbitration, International Law Association (British Branch) conference, University of Essex, 2015
- Investment Treaty Obligations, International Law Institute, 2013
- International Law and the Protection of International Investments, World Trade Club, 2013
- The WTO and Investment Treaty Arbitration, Ewha Womans University, 2013
- Methanex: Context and Legacy, Korean Commercial Arbitration Board Forum on Investor-State Disputes, 2013
- A Primer on International Investment Law, Seattle University School of Law, 2013
- A Fissian View of Investor-State Arbitration, National University of Singapore and George Washington University, 2012
- Microinvestment Disputes, Seattle University, 2011
- Commentator, Institutionalizing Asia, University of Washington School of Law, 2010
- Darfur, Divestment, and Dialogue, University of Connecticut School of Law, 2009
- The Politics of Divestment, George Washington University, 2008
- Moderator, Enforcement of Investment Arbitration Awards and Challenges and Annulment of Investment Arbitration Awards, Asia-Pacific Economic Cooperation Workshop on International Investment Agreements (Washington), 2008
- History of International Investment Law, The ICSID and MIGA Conventions, Fair and Equitable Treatment, and Most-Favored-Nation Treatment, Asia-Pacific Economic Cooperation Workshop on International Investment Agreements (Singapore), 2008
- Commentator, State Consent by Legislation to Investment Arbitration, Second Annual Conference on Investment Treaty Arbitration, 2008
- Here There Are No Cows: Unneighborly Decisions as a Prism into Contemporary Issues in International Law, Wesleyan University, 2008
- The Investment Case of the Year, University of Connecticut School of Law, 2008
- Investment Policy and Human Rights: The Sudan Accountability and Divestment Act, University of Pennsylvania Law School, 2008
- Introduction to International Investment Law, Project-Specific Investment Agreements, Procedural Aspects of Investment Arbitration, and Concluding Observations, International Law Institute, 2007
- Arbitration of Investment Disputes, International Law Institute, 2006
- Investment Climate: The Role of Investment Treaties, International Law Institute, 2006
- Two Roads Diverged in Bretton Woods: The Role of Private Actors in WTO Dispute Settlement and ICSID Arbitration, American Society of International Law, 2006
- The International Investment System: Substance and Process, International Law Institute, 2006
- International Organizations as Law-Makers: The Role of the Private Sector in Making International Law through ICSID Arbitration, Columbia University School of Law, 2006
- Investor-State Arbitration, George Washington University Law School, 2006
- The Role of Private Lawyers in WTO Dispute Settlement, Salzburg Global Seminar, 2002
- US Antidumping Measures on Stainless Steel from Korea: The WTO Panel Proceedings, Japan Fair Trade Center, 2001
- The Constitutionality of NAFTA Chapter 19, Japan Fair Trade Center, 1998
- US Economic Sanctions: Why They Matter to Japanese Businesses, Japan Fair Trade Center, 1998
What Our Clients Say About Perry
Source: Chambers 2024
- Perry Bechky is wonderful. He has great knowledge. I love working with Perry. He’s very involved in the area. He can give quick, wonderful, precise advice. He’s very responsive and very practical in terms of his advice.
- He is an incredible professional with an encyclopedic knowledge and understanding of cross-border commercial issues, especially as they relate to general US sanctions issues and OFAC.
- With Perry Bechky you are in great hands. He delivers on what he promises. Perry is very diligent and detail-oriented, but he doesn’t lose sight of the big picture. Also, he knows which aspects can be better covered by other members of the team.
- Perry Bechky is a standout. He delivered a work product on an extremely quick turnaround and made himself available for late-night phone calls.
- Perry Bechky has been in this space for a long time and is great at what he does.
- Perry continually exhibits his depth of knowledge via the matters he handles for us. He is clearly adept at navigating the nascent and unprecedented complexities of the sanctions at issue while remaining cognizant of our business and operations. Perry’s advice illustrates that he realizes our necessity to understand and comply with applicable restrictions. Perry is easily reached and consistently provides responses and deliverables on a timely, and often urgent, basis.
- Perry’s knowledge and experience in the sanctions arena is exceptional. He is very pleasant to deal with and is responsive, which as a quality is invaluable when operating in a fast-moving environment. Perry is always very responsive and regularly made himself available at short notice.