IME, it basically is for all practical purposes. I can generally see the muzzle flash of Sims with my bare eyes in the dark at CQB distances, and can definitely see it while looking at it with NODs, which is about the same as suppressed rifles IME. I've been shot at by overwatch elements before specifically because they stated they could see my muzzle flash, even though they could not seem me directly prior to my pulling the trigger, due lighting conditions inside versus outside the shoot house. Neither Sims nor suppressed live ammo give out a large amount of flash (particularly when using low flash duty ammo), generally small enough of a visual signature that you won't see it under NODs if it's not directly in your FOV, especially in mixed lighting environments as found in urban areas. Thus, passive aiming with either setup would give you additional obfuscation of your position compared to active aiming.
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