Those are good comparison shots, Wookster. It almost convinced me, but it could just be the lighting and face paints that make them look different. I still think it could be the same sculpt.
I snagged the red headed version's head on eBay with the intent to replace the head of my CG-EX3 Ash. She's a definite improvement, but I can't overlook her bulbous nose. That was the one thing that really bothered me about the Elizabeth Swann figure this head sculpt seems to be reused from. There are some slight differences, such as the more open mouth, and the more narrowly open nasal passages, but this appears to be the same head. The nose is a bit more rounder than Keira's (judging by the numerous images I've seen of her), but the bigger problem may be the narrowness of the nasal passages.
Still the head is beautiful and her look (hair and eye color included) works for my Ash. Now I just need a Triad Toys Otaku that color matches and some complete black gloved hands to get her the way I want.