They do use it but you can force passcode requirement by holding down the power button until 'slide to power off' appears. From daringfireball:
'(One way the scam would run: Chat up the victim in a bar, and offer to use the target’s phone to snap a photo of the victim and their friends. Surreptitiously lock the phone out of Face ID when handing it back to the victim. Then, when next the victim wants to do anything on their phone, they need to enter their passcode. Either the thief or a partner in a team gleans the passcode. Then they steal the phone, knowing the device passcode.)'
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