When U.S. District Judge Alison Nathan late last week dismissed the criminal case against Ali Sadr Hashemi Nejad, her order brought some welcome closure for the American-educated entrepreneur born in Iran and his lawyers at Steptoe & Johnson, a team led by Brian Heberlig and Reid Weingarten. 

The ruling was a dramatic turnaround for Sadr, who had been found guilty in March by a federal jury in Manhattan of violating the U.S. sanctions regime against Iran in connection with a $475 million contract an Iranian company controlled by his father entered into with a state-owned company in Venezuela to build low-income housing. Since the transaction was conducted in U.S. dollars, prosecutors in the Southern District of New York had tried Sadr on the novel theory that he had induced U.S. banks involved in the transaction to export their financial services to Iran. That, prosecutors argued, put the banks at risk of potential penalties from the Office of Foreign Assets Control or OFAC, the arm of the Treasury Department which oversees economic and trade sanctions based on US foreign policy.