Let's say I live in Russia and I use Gmail. My Gmail has my phone number for recovery in case I lost my Gmail password.
Obviously if Russian police want to access my Gmail account then they can produce a SIM card for my name and receive the reset code.
So, there is not much to protect yourself. You need to keep your Gmail account secret so that they would not know for what account they'll make a reset.
But if I use a foreign SIM card, like a German SIM card, how secure would be my Gmail account? What do they need to get the reset code from my foreign SIM card? Assume that they have physical access to my SIM card, that the phone number is not printed on the SIM card, and the SIM card is protected with a 4 digit PIN.