> which should be sufficient enough to comply with GPL
this is an age-old debate. Some people say that it is e.g. legal to make (redistribute to precise) a GPL device driver for windows, and some argue that it is not, because the whole kernel should then be GPL.
But in Windows drivers are binary files which talk to the kernel through an API. Not much different than a binary user mode application. If binary user mode applications written in GPL are ok, then so should this.
But the actual syscall is made by a Windows user mode library - kernel32.dll/... So your GPL user mode app calls directly into proprietary Windows library.