It certainly could be.
The sound clip you hear in films when a plane nose dives is from a specific device called the “Jericho trumpet”, fitted to some German WW2 dive bombers. It’s only purpose was psychological, as you’d know there was an incoming bomb.
Mortar fire is similar, it’s not too accurate, but to have a constant barrage is incredibly demoralising as each whistle means you might be dead in a second.
The fins will be making the noise, but it’s a handy side effect and I don’t think anyone is in a rush to make them quieter.
They typically don’t. However, in WW2, countries would often stick whistles onto their bombs in order to make the bombs more terrifying to their victims.
If you’re talking about movies and TV shows, it’s an affectation to convey to the audience that a mortar/artillery round is incoming; otherwise, there’d be no way to know.
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