Technically, no, in actuality, yes.
Actually, I never really thought about it that much. I'm an AP holder, but last time there I bought two 3-day passes for my brother and his girlfriend to go with me one day, so now I have two 3-day passes with 2 days left each. This weekend I'll use them to take my mother and father for one day. Is that transferring them? I own them now and have always owned them, it's just I'm not the one who actually used them, so they're never really transferred ...
Of course the ones I bought from AAA said the same thing, but AAA transferred them to me ... I think that demonstrates how little enforceability that "contract" actually has since Universal does in fact allow transfers in that case ...
Anyway, being that you're the same family, I don't think in a million years Universal would ever catch you or even care if they knew. They have much bigger problems with people selling their tickets on Ebay and such ..