For what it's worth, they're trying to fix that with Android 15. Not sure if this is one of the features they'll also be back porting to older phones too like this article briefly touches on, but either way it sounds like if you factory reset the phone, it can't be set up again unless they know your login: https://www.wired.com/story/android-15-theft-detection-lock/

Google says in a blog post, the company is adding four data protection features that can help keep your information locked down. The first stops your phone from being set up after a factory reset, unless the person knows your login details. “This renders a stolen device unsellable, reducing incentives for phone theft,” Google vice president Suzanne Frey writes.