The app hast to make $1k on its own and pass ‘quality app’ certification process (i.e. you can’t publish a $10 app, buy 100 copies and collect the remaining $9k).
On the other hand, you can get sources for an existing crappy iOS app with custom skin for under $1k, spend few hours to add/update SDK’s, publish and collect few $K as long as the name and the icon are decent.