I don't think the car ever determines it is on ice, however the controller does have a wide traction range (too wide IMO). The fastest way to stop on ice and gravel is full lock up, ABS can extend stopping distances by 2x to 3x if improperly applied (not allowing enough lock between releases).
I think it is a flawed design, but you are probably right that it goes back to liability. If it was a true 4-channel ABS controller then it can individually give full stopping potential to each corner. However doing that could cause the car to pull in one direction or the other so they create artificial limits on how much the bias can be left to right, front to rear. Given the large rear brakes, their maximum limit may not be enough in the extreme cases especially front to rear.
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