I feel that as a passive quality, it's technically questionable, but as as Balience standpoint, I see little problem, namely that yes it is playing to obtain an advantage but then why shouldn't he? Considering he's giving up...
A better weapon (generally 2 handed weapons are better as pure combat weapons.)
Wielding 2 one handed weapons (harder difficulty, potentially more damage)
Interaction with objects. (Something a character can do with one handed and 2 handed weapons, not duel wielding.)
Two manvours to draw both weapons.
Range (short/medium, though there is one long pistol.)
Though that being said, though generally the raw is that you must wield both weapons, not merely hold it. Thus all penalties should apply. That being said, I am in the camp that prefers rules of cool, the same reason I am trying to design an design an attachment to a dueling pistol to make it a six shooter.
So do what's fun, just as said, apply whatever you give to your npc the same rules your player has.
Edited by LordBritish