Interesting thought. Perhaps this is because the majority of counterfeits are cast, if counterfeit coins were struck, they would probably have cartwheel luster.
....as long as they're struck from similar alloy, at similar speed and pressure to the original press, from dies having a similar level of preparation. At which point there would be created concrete die pickups similar to any Morgan which any decent VAMmer could isolate and compare to known die pairs. The better they do, the more likely we are to catch them at it, as long as we're vigilant. The more accurate the copy, the more finely we can compare to known hub features.
It's actually the struck examples I'm referring to. I've seen images of struck counterfeit CC Morgans in counterfeit GSA holders that had no cartwheel lustre as well.
Some of the presses we used at our mint in Manila were bought as scrap and are now refurbished and striking counterfeits with luster exactly as if they were struck on our own equipment because they were.