Not quite. The DPO is a different subject matter. Article 27 stipulates that data processors outside the EU should designate a representative, a whipping boy,

Not quite. The DPO is a different subject matter. Article 27 stipulates that data processors outside the EU should designate a representative, a whipping boy, if you will. The representative should be subject to enforcement proceedings in the event of non-compliance by the controller or processor. In most cases it would probably be the same person fulfilling both the representative and DPO functions but those are actually two separate roles.