I don't think it can. What would the financial motive be? With Google it is more ads with Adsense on their crappy SEO site. With Kagi, we actively downrank such sites out of existance.
That or it'll be a cat and mouse chase like cname cloaking/proxying rendering those harder to statically detect.
Also Kagi lets me blacklist domains myself if I want stricter rules than Kagi already provide.