interpretation is correct. This article names many cases: www.eff.org/deeplinks/20... I imagine (and seem to vaguely recall but my brain might just be making things up) accounts terminated (necessarily globally) for similar reasons under criminal law as under sanctions law.
Another article I had saved on the speech-related impacts of sanctions: www.lawfaremedia.org/article/how-... (EU has a Blocking Statute to combat extraterritorial sanctions regimes BTW.) Also makes me curious how §230 and DSA immunities apply to sanctions law. Ban on general monitoring would
suggest intermediaries don't need to seek out accounts of sanctioned entities and instead need to be notified (and then go in on an also kinda banned fact-finding exercise?). (Though I actually don't understand exactly how §230 interacts with criminal law.) While not really a content takedown,
taking away access to (non-public/SNS) intermediary services (like the ICC prosecutor's email account) seems like the same sort of issue, with speech/association-related impacts. Domain name seizures (and similar seizures of property) may also have similar takedown-like effects. But that's probably
beyond the scope of what you're asking. As a bonus, and while on the topic of sanctions, one might wonder how interoperability would work with a sanctioned foreign SNS. Meta's Article 7 DMA reference offer rules out interop sanctioned entities... Doubt that's permissible under the DMA though.
Oooh, that one sounds like a potential hard conflict. If EU law requires interoperating with someone/an entity on the export controls list? I think that's a big deal, like a countries-need-to-sort-that-out level deal. Or if we had all sane countries that would be how this should work.
Some of those export control laws are criminal, which puts them outside of CDA 230. But also for some the prohibited export can truly be the service itself (not just user content), so it'd be outside 230 for that reason also.