[sipefree]

It's free to get a cert from Apple to sign your app, but you have to be a registered developer (which is also free).

Essentially, you have to be a real person who can be identified if they produce malware.

[smackfu]

I'm curious how real you have to be... since the easy way around this is to get 10s or 100s of accounts and release multiple versions of your malware.