Well look at it this way. Any air that will be coming off that heatsink will be hot air, do you really want that blowing over your OC'd ram? Have it point to the back of the case where there is (typically) an exhaust fan. That way it will get that air out of the case quicker, and make for a cooler case/proc/components.
And typically a normal HSF will blow air downwards, not upwards