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I'd certainly believe they have Android and iOS exploits allowing them to brute force PIN codes and passphrases at the rate supported by the hardware. Firmware-based throttling by the iPhone SEP could be bypassed by another exploit. Is there really any surprising about that?
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Most Android phones have no throttling beyond the cost of on-device key derivation once an attacker controls the OS. Many Android including the Nexus 5X and 6P didn't implement true hardware-bound encryption and can even have the on-device aspect bypassed via a TEE exploit.
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