I'm no legal eagle, but I would say you are spot on with that witchdoctor - after all think about it.
You can buy a portable transceiver for aviation purposes, which you could use to listen only, but it would be easy to press the PTT button, and yet you cannot buy a receiver ??? IT's common sense - if your a pilot, I don't see why not.
Another point - I think you DO need a R/T license before buying a transceiver - imagine if one of them got into the wrong hands .....
Happy listening !