Theoretically sure, but without a title they'd never really get to play in any online money tournaments, and to get a title they'd have to play over the board g

Theoretically sure, but without a title they'd never really get to play in any online money tournaments, and to get a title they'd have to play over the board games where cheating would be a lot harder. So it would be a lot of work to be a very strong online only player that doesn't make any real money. As a proof of concept it would be interesting to create an AI that has an undetectable natural progression and human-like play style.