Why not have a phone with three SIM card slots? Avoid the kickback from the carrier to Apple.
Why have SIM cards at all? What's the point in keeping credentials from the legitimate customer? Store Ki directly on device. Modern phones have HSMs so key will be kept as secure as with a "real" SIM HSM, and bet phones could do the necessary crypto just fine. Sure, a customer will be able to clone their own SIM card and share it with others, but I don't think that's a major issue. Logging onto the network with a cl…
If you have the Ki on the device, you're effectively going back to CDMA-style devices, whereby you need the carrier's assistance to move between handsets.