That situation is quite different. The US is using its significant power and weight to coerce those non-US banks into compliance with FACTA. Those banks don't have to comply, but they want to do business with the US and US companies, then they don't have much of a choice.
It's not like they just made a law and now insisted it applies globally, which is what the EU did.
It's not like they just made a law and now insisted it applies globally, which is what the EU did.