Possible. Definitely very similar.I was under the impression it's just the modular bumper with the same winch mount bolted to the recovery points. (Same one that's on the Overland concept for instance.)
You can see on the original, the flat base frame looks to be three pieces welded together, with a decorative forward offset, the sides standing out from the front cross member, the new one is missing that. This just looks like value engineering, simplify the design to lower manufacturing cost or those could just be decorative plastic end caps that are missing on the overlander.Possible. Definitely very similar.
It looked to me like there was more space beneath the winch to not block the ACC, but hard to tell for sure with these angles.