[Topfi]

I am by no means an expert, but as far as I am aware FATCA violations carry slightly higher penalties then what you suggest and are very much not limited to "you can't do business with the US government anymore".

Also, even if "you're a credit union servicing a small town in Brazil" and even if the penalty was as limited as you think it is, I doubt even a smaller institution could survive loosing access to US securities, etc.