A bank with zero US financial system exposure can’t be penalized under FATCA because they have nothing to penalize. FATCA only works because banks have exposure to US assets.
The unintended consequence of FATCA is that it is dramatically harder for a US person to do any business with European banks — banks have closed accounts in order to reduce operational risk. So this “good law” (occurring to Democrats that passed it) actually made it much more difficult for Americans overseas and American companies who need overseas banking.
GDPR could be considered similar — it won’t have any jurisdiction if the company involved has no EU presence, but it could result in companies denying services to EU persons based on operational risk.
People should have thought this through much better.