I see a couple of problems with jfgambit's solution.
One, I don't think Access will let you disable a control while it still has focus (which I think it does at the After Update stage). I tried his code and got an error message to that effect.
Two, and more importantly, if you COULD disable it at this stage, the user could not correct the situation if he/she accidentally checked the box. The user should be able to correct a mistaken check at least until they leave the record.
And three (I know, I said there were two problems, so sue me) if a user checks the box, leaves the record, and realizes his mistake, then you have a problem that the system administrator will probably have to solve. The correction would have to be made directly into the table.
The Missinglinq