iCLoud can be disabled by MDM profile installed by Apple Configurator at setup.
After an MDM profile is created by someone technical, it can be emailed to the non-technical user and installed with a few clicks and passcode confirmation.
I thought MDM was only for enterprise businesses and schools and universities, but I may very well be mistaken about that.
https://support.apple.com/guide/apple-configurator-mac/welco...
If you're threat actor has the resource to break that, get a CC or a good lawyer on retainer I guess.
No way to add a WiFi profile, thus no way to use an iPhone as a remote. No ethernet available either.
Configured a WiFi profile, uploaded to the Apple TV and could finalize the setup.
It’s quite a powerful too for initial setup.