I suspect that this is simply an oversight on the part of Embarcadero. The main focus of the large address aware changes that they made were the IDE. Typically it was the IDE that was susceptible to out of memory failures. I suspect that it is very rare to encounter such failures for the command line compiler.
Now, the compiler code is executed in the IDE process, bds.exe. Under default settings, when you compile a project, an external process is not created to perform the compilation. Instead, if you look at the modules loaded by the IDE, you will see dcc32230.dll and dcc64230.dll. The DLLs contain the 32 and 64 bit Windows compilers. They contain the same code as dcc32.exe and dcc64.exe.
Since the compiler code for dcc32 and dcc64 can exist happily in bds.exe, a large address aware process, it is hard to imagine that dcc32.exe and dcc64.exe will not function under large address aware conditions. Therefore I believe it to be a simple oversight on the part of Embarcadero that these executables do not ship with the large address aware PE flag enabled. I suggest that you submit a bug report / feature request.
So I think it very likely that you are safe to modify the executable files for dcc32.exe and dcc64.exe to enabled the large address aware PE flag. When you do this, you would be wise to perform some top down allocation testing to stress test the change. Details can be found here: https://stackoverflow.com/a/545097/505088.