Earlier quoted context omitted.
Eh, fake receipts are fairly easy to knock out. When I managed a hospital's iPhone deployment I made it a point to always back up our receipts electronically because I have... had to make quite a few emails to AppleCare Security to release a few Activation Locked devices. It's not a terribly difficult process once you've done it a couple times, and I reasonably think I could release as many phones as I wanted these d…
The fake receipt Is the easy part, it’s the staffing and logistics and risk to send people into lots of Apple stores to use them. One, sure. But an organized theft ring stealing 1000 iPhones a month is probably not going to work at that scale.
Imagine the false docs are often accepted, rather than triggering a criminal prosecution. The practical maximum downside may be mere impoundment of the device, rather than a conviction/jailing.
(And, even that would require Apple's policy to be to assertive & confrontational: "you presented us suspicious documentation, we're holding this device – that you carried here, in your possession – until police sort it out." Does Apple want to take the risk of that backfiring on them? Or would store staff, in practice, simply say: "we can't accept that documentation, you and your device should leave.")
Then Apple's lenience here will support a positive resale value of stolen devices, enough for the weakness in their systems to be exploited.