They sure can, but they will be liable if the wallet is modified to cheat.
At the minimum they need an integrated chip, code, data and processor on board with no logic interface to capture instruction streams. Then, add finger print, a button or two, and a digit display.
The contract is simple, no spending over $100, and the vendor insures against theft of keys. It is easy enough to pick a design point where wallet price, guarantee, security, and consumer needs match; with acceptable forgery risk.
Smart wallet rules are simple,. just not formalized.
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