Not having a central controller multiple subsystem vendors would have to cooperate using an agreed DMA communication protocol to monitor you and send the information back using the wifi/ethernet chip. Possible but unlikely.
The IOMMU functionality is built into the Platform Controller Hub, which is between the baseboard management controller (the ARM) and the main processor.
Theoretically it would be possible to prevent DMA between the two, but it is highly doubtful Apple would program it that way.
*edit sorry I am wrong. DMA seems to bypass the CPU [1]
1. https://www.csoonline.com/article/2607924/security/stop-snea...