Yep, it could be. That’s really tough to “feel” and also tough to see. I’ll never forget one of the early RDT videos where Troy demoed what he thought was a DSX tremolo but upon review in super slow mo you could see it was DBX. Troy has really high quality filming though.
Another possibility is that it’s trapped. That would be easier to tell especially if the pick strokes are not kept intentionally small. If we play on one of the inner strings, a USX or DSX tremolo will hit just one of the adjacent strings. Then we’ll know! If it his the “thicker” of the adjacent string (on upstrokes), it’s DSX. If the “thinner” adjacent string (on downstrokes), it’s USX. If it hits both adjacent strings constantly, we’re trapped. In a wrist motion like this, all we’d need is either a little bit of pronation to give us DSX. Or, possibly, a little supination to give us USX (though that often messes things up, changes the motion, and folks still don’t have a USX motion).
If I were a betting man, just after seeing hundreds of these things, I’d say this OP motion is probably a highly capable DSX motion, with potential to pivot to USX or even DBX or mixed escape. It’s a really great looking wrist motion.