There should be a certain amount of bitcoin involved or transferred to another address before the owner of the said address is prosecuted, otherwise the said Iranians could go and spend a couple Satoshis and turn anyone's address into a recipient of the dirty coins listed on the OFAC. It's quite vague on the Fed's part to really address this issue since sooner or later, a huge chunk of the network would be affected and almost everyone can be prosecuted.
Idk what came to their mind but this is not going to work in the long run.
I agree this isn't going to work in the long run. For one, bitcoin can always add additional security measures. What I'm worried about is the US government perceiving bitcoin as a threat and then using anti-money laws to prevent adoption in the US before these security measures are adopted. I am not aware of a de minimis provision in current law that prevents prosecution as long as transacted amounts are below $X so I think what you described about Iranians turning every wallet into a dirty wallet is in fact possible.