Well, I said "closer", not an exact analogue. They're pretty close equivalents, though, as most Windows programs don't actually call syscalls directly, but link in an OS-provided DLL and call an exported symbol from it, with the userspace to kernel bits abstracted away from most user programs. Wine (mostly) re-implements those DLLs, effectively re-implementing the Win32 API (a userspace API) in Linux's userland.
(programs are allowed to call the kernel directly, though, and Wine has to handle those cases esp. for DRM/anti-cheat code in games that poke at the kernel directly, recently Linux was patched to allow userspace programs to directly handle syscalls [0][1], making Wine ... closer to a WSL1 equivalent?)
[0] https://lkml.org/lkml/2020/8/10/1323
[1] https://github.com/torvalds/linux/blob/master/include/linux/...