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Honestly: what banana republic do you assume the EU is? No way a 20 million euro fine for a first infringement of a small company would be seen as reasonable. Scaremongering neither helps you nor anyone else here.

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If they intended for there to be safeguards, those would have been built in. They. Are. Not. There.

A 20€ million fine for that would not be proportionate, nor would they have taken into account the relevant factors ("the nature, gravity and duration of the infringement [...] as well as [...] and the level of damage suffered by them").

Edit: typo (proportional->proportionate)

A 20€ million fine for that would not be proportionate

By whose definition? Germany might disagree with you.

Can you point to any excessive fines imposed by the German regulators under existing law?

No, but they've never had the extraterritorial reach being claimed by the EU within the GDPR either.

I'm sure technically you are right on the written wording of the law, but you can be technically right on many subjects and make the wrong business calls. Avoiding a vanishingly small regulatory risk by making real damage to your company seems like a bad call.

You could totally eliminate the risk of meteorite impact on your business by relocating down a mineshaft...

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