You used to be able to pull out your phone and play Disney soundtracks or Taylor Swift music which would result in the video being non-monetizable. But improvements in audio isolation techniques have now defeated this countermeasure. Being a professional annoyance is once again a career choice.
Edit: this is one instance I've personally seen: https://www.instagram.com/p/C7IEFxQSJQw/?hl=en&img_index=1