https://bugs.winehq.org/show_bug.cgi?id=47198
--- Comment #116 from Zebediah Figura z.figura12@gmail.com --- (In reply to Zebediah Figura from comment #115)
From the analysis shared with me by Andrew Wesie a couple years ago I believe there were direct SYSCALL instructions. Note also the contents of attachment 64481 [details]. Perhaps that's changed since then.
Okay, comment 90 explains the issue (buried under all of those user reports), I guess the SYSCALL instructions were in a fallback path. The normal path doesn't jump to 64-bit code at all, but uses the 32-bit ntdll. So we don't need bug 48291 or bug 52483.