https://bugs.winehq.org/show_bug.cgi?id=39093
--- Comment #3 from Dmitry Timoshkov dmitry@baikal.ru --- (In reply to Michael Müller from comment #2)
I am not 100% sure why the program does this, but it seems like the game calculates some offset in the mapped kernel32 module and then maps the dll manually:
Sounds similar to the bug 29688.