AFAIK all it takes to bypass Gmails spam filters is to resend the same scammy email that was Flagged but using a different email address. I get the same kind of scammy emails, flag them as spam, and then a couple days later, Gmail lets the same email in though it is coming from a different 123134r12345124@blahblah.com address.
In my experience the new strategy is to just send an email with no body, no title, optionally with an image of a conventionally attractive lady, in the hope
people respond after which they're automatically whitelisted (as there's now a 'conversation').
I get a lot of those. Never download the image so I don’t know if there is an attractive lady or not. I do always mark them as phishing spam for gmail but it just keeps delivering more. I lost count of the free Yeti mugs I’ve missed out on.