This card wins my "I didn't think it would be as good as it is" award.
I was seriously underwhelmed when this card was spoiled, but having played with it a bit, I find myself really liking it a lot.
It punishes NBN a lot. (Which fits, since it came out in NBN's deluxe expansion.) Tollbooth is a fantastic ice specifically because it can be counted on to generally cost the runner around 7 to break, even with a good breaker. Dropping that to 4 is huge. And not just Toll Booth! Data Raven loses a lot of its sting. Pop-up Window suddenly stops making money. Turnpike no longer has its tax.
But even outside of NBN, all of the grail ice is stuck at one subroutine. Quicksand can't grow. And Komainu, much like Troll both end up effectively blank.
The active ability is less likely to be useful to runners who aren't using Apex's tools, although it's a good alternate use for anyone running Aesop's Pawnshop or Chop Bot 3000, if the corp doesn't seem to have any Toll Booths.