While Europe has been gripped by the fear that a U.S. president could one day “pull the plug” on its digital infrastructure, Professor Theodore Christakis shows in a recent Lawfare article that the European Union has, in fact, just demonstrated its own capacity to do something very similar. In “When Governments Pull the Plug”, Professor Christakis examines how an EU sanctions decision targeting the Indian oil company Nayara Energy for its links to Russia led to the suspension—then quiet restoration—of Microsoft services that were critical to Nayara’s operations. What might appear at first glance as a technical sanctions episode is, in his analysis, a real-world test of what a digital “kill switch” looks like when exercised by a democratic bloc.
Theodore Christakis situates this precedent within the broader European debate on “digital sovereignty” and strategic autonomy, in which reliance on U.S. hyperscalers such as Microsoft, Amazon and Google is increasingly portrayed as a security vulnerability. He revisits earlier controversies, including the dispute around alleged disruptions to the International Criminal Court prosecutor’s Microsoft account following U.S. sanctions, to show how concerns about American leverage over cloud infrastructure have shaped Brussels’s thinking. At the same time, Christakis analyses how U.S. cloud providers have tried to assuage these fears through “sovereign cloud” offerings and bespoke European commitments promising continuity of key services, even amid geopolitical tension.
By unpacking the legal mechanics of EU asset-freeze measures and how they can extend to digital services, Professor Christakis demonstrates that the ability to cut off core digital tools is not an exclusively American phenomenon, but a structural feature of a world in which sanctions regimes, platform governance and cross-border infrastructure are deeply entangled. He argues that the Nayara case, alongside earlier examples such as banking and software shutdowns in other sanctions contexts, shows that multiple jurisdictions now wield something akin to a kill switch—often indirectly, through the compliance decisions of global technology companies.
For now, Professor Christakis emphasizes, outright sanctions-driven suspensions of core digital services remain rare. Precisely because they are exceptional, he argues that democracies should resist normalizing kill-switch solutions or building public policy around routine service cutoffs. The wiser course would be to keep shutdowns as a genuine last resort, while prioritizing cooperative legal arrangements that limit extraterritorial spillovers, reduce collateral damage in third countries and protect the continuity of essential and humanitarian services. Rather than drifting toward fragmented, “air-gapped” sovereignties, Theodore Christakis calls for a new international framework to discipline these powers and embed them within clear, predictable and rights-respecting rules.
To read the full article on Lawfare, click here.
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