Depending on how you count, surely dd should take the cake? Otherwise, you're just including the group of commands that uses arguments as a command language, and I don't think that's actually such a small group; ffmpeg does the same thing, too.
I mean, find uses parentheses for forcing evaluation precedence, e.g. -foo -or \( -bar -and -baz \). That's pretty unusual.
$ find -type f .
find: paths must precede expression: `.'
$ git grep Congrats -i
fatal: option '-i' must come before non-option arguments
They just seem to produce a syntax error no matter where I use them. But if they have no purpose, then why not simply treat them as nonspecial characters?
E.g.
echo hello :-) ;
echo "hello" ":-)";
?