I think that second (speculative, of course) step would be the more worrying precedent: if the use of technical infrastructure also used by designated groups was formally made to be incriminating/right-waiving. Why wouldn’t that apply to Signal, for example? The OP suggests the dividing line should be between true infrastructure open to all, including unsavory actors, versus tools that advertise services to a particular faction. It’s not an entirely disagreeable distinction, but I think in practice it’s rather fuzzy (Moxie of signal is/was rather far left himself, if I recall).
EDIT: Re-reading the document, the state department emphasizes that a/I “manually vets all potential users.” OP’s distinction stands for now.
Signal doesn't knowingly and deliberately provide services to any organization, let alone one formally designated by the US and the EU. The whole point of Signal is to eliminate all pretenses of the service knowing who its users are or what they're doing. To the extent that's also true of Autistici Inventati, the OFAC designation is invalid.
[0] https://www.state.gov/releases/office-of-the-spokesperson/20...