The function "replace keys" can have any other programmable feature attached to it. Wiping out all preexisting data, reseting the phone to factory settings, and sending a message to the original owner is all possible and would make any sneaky behavior very un-sneaky. They could even require some form of 2auth or other technique that people use to authorize themselves to banks in order to get the unit-unique key to make the TPM memory rewritable. GPLv3 don't require that installing new keys are easy, but the real owner must have a method to do it.