But Apple does give you leeway. You can distribute up to 100 copies outside the App Store, and they're now adding the ability to distribute as many copies as you like to in-house users over WiFi:
What you're calling leeway, I would call 'crumbs'. I'm not convinced in the slightest that that sort of world is one I'd want to inhabit or recommend to friends.
http://www.apple.com/iphone/business/preview-iphone-os/
Such apps are not bound by 3.3.1.