Hi Ryan, If you're using SFDC (or other CRM), you can create a field on Accounts called "type" with values: customer, prospect, lost deal. When this field is synced to Marketo, you can use it in smart lists (Type no equals to "Customer"). You can maintain this field manually or via workflow rule (let me know if you need any assist with the workflow).
I'm not familier with the smart list limitation, but we use the method above in smart lists and segmentations.