Resolution: On Windows Engines, when running native code, the PATH environment variable does not contain c:\winnt\system32.
The Engine PATH is purposefully "sandboxed" to prevent execution of unauthorized programs. Authorized programs must be copied into the LibDir or the LibDir must be edited to include the target directory.
Note that the winntsystem32 library is available for linking when running cppdriver jobs which are searching for dependent DLLs. However, any subshell process will only have access to the Engine JRE directories and any directories that are part of the LibDir. So, if you were to launch a subprocess via PDriver or via the CreateProcess() API call, it would require that dependent DLLs be available in the LibDir. Invoking an API call from within a CppDriver tasklet's service() method will be able to resolve DLLs in the System path.