I think AA knows they need to honor this. Right now they're making a bit more difficult so that they can minimize their losses.

I'm not sure about the consequences from DOT but AA has cancelled held tickets and will probably cancel confirmed tickets. AA will then tell DOT 'oops, sorry, we made a mistake and we'll honor and get those back if they 'still' want to go.'This way some people may never bother reinstating or calling back.

I'm thinking AA has nothing to lose by doing this.