Is this a swirl in my banned art gengar?

Hi new to collecting or rather, just looked through a collection I’ve had and not touched since I was a kid. Is this considered a swirl on my banned art gengar? It’s very light so wasn’t sure. (I know it’s not a great grade because of the scratch but it’s been sitting in a kids binder for 20+ years) it’s been shipped off to get graded anyways.