No it's not.
Don't forget that this is a PC keyboard not an Amiga one. It just has the Amiga keys instead of the Windows logo ones for means of nostalgia and emulator fun.
Then what's the point of Amiga keys if the layout doesn't match the original? If you want it to look like an Amiga, then make it so... don't quit halfway through.
Besides, I think the CTRL keys is much more conveniently placed on the Amiga than on a PC keyboard. The pinkie instinctively rests on the CTRL key, making it easy to hit CTRL+C, CTRL+D, etc. Who uses the Caps Lock anyways?
(Disclaimer: I don't mean to be rude, I'm just an "all the way or nothing" type of person)