Moderation tools arent limited to specific PDS's, labels are public. If an account has received many reports it will have been labelled by Bluesky's moderation account and other independent labellers. A PDS can check against these before allowing an account to migrate if they choose to. I'm not sure any are currently doing this, but this is something that can absolutely be improved in current implementations, not an inherent limitation of the architecture.
*requires your own PLC key, which the vast majority of users do not have, protonmail has good prior art here (imo)
I'm not aware of what Proton does here, I'll look into that.