Case Western Reserve Journal of International Law 52 (2020) Crime as Cognitive Constraint between Global South and Global North contexts. 109 Leaving aside the realpolitik that likely moved platforms to regulate (or not regulate) the speech of state actors as platform users, the implications on corporate responsibility are still worthy of examination. Whereas corporate accountability was originally envisioned to regulate corporate interference with the exercise of individual human rights, 110 Facebook’s ban of a state actor’s speech shows a corporation taking on the task to regulate state action, including in fulfilling the latter’s duty to protect human rights. One important question with respect to regulating social media that fosters atrocity crimes is how international law should apply to the work of platforms. Relatedly, the FFM recommended that Facebook and similar companies “apply international human rights law as basis for content moderation.” 111 This suggestion echoes the stand of the UN Special Rapporteur on freedom of expression, non-governmental organizations, and commentators on the subject. 112 Some portions of 109. Interestingly, Twitter banned Syrian president Bashar al-Assad’s account after it mourned the death of Iranian Major General Qassim Soleimani due to a targeted US drone strike. Twitter also temporarily suspended or restricted the accounts of the supreme leader of Iran and leader of Venezuela’s national assembly. See Ben Norton, Under US Pressure, Social Media Companies Censor Critical Content and Suspend Venezuelan, Iranian, and Syrian Accounts, THE GRAYZONE, (Jan. 12, 2020), https://thegrayzone.com/2020/01/12/us-pressure-social-mediacensoring-suspending-venezuela-iran-syria/. Instagram similarly removed accounts expressing support for Soleimani, citing US sanctions against Iran as the basis. Casey Newton, Why Activists Get Frustrated with VERGE (Jan. 14, 2020), Facebook, THE https://www.theverge.com/interface/2020/1/14/21063887/activistsfacebook-iran-free-speech-authoritarianism. In contrast, despite President Trump’s Twitter statements on “quickly and fully” striking back and “perhaps in a disproportionate manner” against Iran should it retaliate for the Soleimani killing, Twitter did not suspend Trump’s Twitter. INTERNATIONAL, 110. See Corporations, AMNESTY https://www.amnesty.org/en/what-we-do/corporate-accountability/ (last visited March 25, 2020). 111. Detailed Findings of the FFM, supra note 7, ¶ 1718. 112. UN HUMAN RIGHTS COUNCIL A/74/486, Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression (Oct. 9, 2019) (discussing the applicability of international human rights law to regulating online hate speech); UN HUMAN RIGHTS COUNCIL A/HRC/38/35, Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression (April 6, 2018), at 15-16 (recommending that content moderation should adhere to the principles of legality, necessity and proportionality, and non-discrimination originally designed for states under the ICCPR); ARTICLE 19, Self-regulation and ‘hate speech’ on social media platforms (2018); Evelyn Mary Aswad, The Future of Freedom of Expression Online, 17 Duke Law & Technology Review 26 (2018). 162