Perry
Bechky

Perry Bechky has 30 years of experience as an international lawyer. Perry has represented clients from over 60 countries on six continents. Perry began his career at the US Department of the Treasury, where he worked for the Office of Foreign Assets Control (OFAC, the agency responsible for administering the major US sanctions programs), the Customs Service, and the US Attorney’s Office for the Eastern District of Virginia. Before joining BCR, Perry practiced for 13 years at two global law firms, taught for five years at two universities, and ran his own law firm for three years. Perry has managed significant international projects before the federal courts, federal regulators, and international tribunals. His projects have included cross-border disputes, internal investigations, international negotiations, management of legal and political risks, national security reviews of corporate deals, prosecution of expropriation claims under political-risk-insurance policies, regulatory proceedings, and treaty-based dispute settlement. His clients have included national governments, international organizations, individuals, small and family businesses, and leading businesses in agriculture, banking and finance, energy, law, manufacturing, real estate, services, and technology. Perry has handled hundreds of sanctions projects, including civil penalty proceedings, compliance, counseling, delisting, expert testimony, internal investigations, interpretative rulings, licensing, and securities disclosure. His experience with sanctions extends beyond OFAC regulations to include such statutes as the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Helms-Burton Act, the Iran Sanctions Act, and the Sudan Accountability and Divestment Act (SADA), as well as international measures like UN Security Council resolutions and foreign “blocking statutes.” Perry regularly co-counsels with sanctions lawyers in other countries on multijurisdictional issues. Perry has also handled numerous national security reviews of cross-border investments by the Committee on Foreign Investment in the United States (CFIUS) under the Foreign Investment Risk Review Modernization Act (FIRRMA) and its predecessor statutes. Perry works closely with corporate counsel at other law firms to represent both foreign investors and US target companies and sellers in a variety of business transactions. Perry assists clients in determining whether FIRRMA requires CFIUS filings, and represents clients before CFIUS in reviews started by both mandatory and voluntary filings. Perry also has extensive experience with trade policy and representing clients in disputes concerning international law, including bilateral investment treaties (BITs) and other international investment agreements, international trade agreements, and sovereign immunity. He lived in Tokyo for six months, working intensively with the Japanese Ministry of International Trade and Industry (MITI) on World Trade Organization (WTO) dispute settlement. Perry drafted the US-Hong Kong Policy Act of 1992 (22 U.S.C. § 5701), which establishes the legal basis for US relations with Hong Kong in light of its special status as a “special administrative region” of China. He regularly writes and lectures about international law and national security topics, especially OFAC, CFIUS, and investment treaty arbitration. Perry has served in leadership positions with the American Society of International Law (ASIL), including service on the Executive Council and as the elected cochair of the Society’s interest group on resolution of international disputes. He is a Cordell Hull Patron of ASIL. Perry has been a term member of the Council on Foreign Relations, a course advisor and faculty member at the International Law Institute, a research fellow at the Fair Trade Center in Tokyo, a fellow at the Salzburg Seminar, and an adjunct faculty member at three law schools and the Stanford-in-Washington program.