https://bugs.winehq.org/show_bug.cgi?id=49970
--- Comment #2 from Gijs Vermeulen gijsvrm@gmail.com --- (In reply to Gijs Vermeulen from comment #1)
I can confirm this in wine-staging 5.18, but not wine-5.19.
This seems to be a problem with xactengine-2.9. Wine-5.19 doesn't have this dll while wine-staging does. The probably tries to use it if it's available and there's some issue there.
* The game probably tries to use it -> I checked with +loaddll and it does do this