Harder to find gullible victims because unlike crypto Twitter this community isn't desperate to jump on the latest Ponzi get rich quick scheme.

I think soon enough it'll be harder for them to spread their messages too. Already relays can implement rate limiting and other gates to keep low hanging fruit out.

Nostr Band in particular uses a ranking system to filter what gets through and can easily blacklist phishing links. I think it won't be long before this kind of functionality is standard in all relays.