Moral culpability in the real world, and comics, are two very different creatures, especially in serial fiction. I'm not arguing that Stevil wouldn't be legally responsible for Hydra's acts, in verse and out.
But rather, I'm arguing, what are his crimes, that he personally undertook and ordered, that make him so vile?
Take Rick Jones. They imply that it was Hydra who ordered his death, and Stevil simply doesn't stop it. Same with Vegas, and to a lesser extent, Jack Flagg. Yes, Cap maimed Jack and his actions led to his death, but before he could pull any trigger (figuratively), Jack's family takes him off life support.
It's his crimes of inaction that frankly lead me to believe that two Caps was a last minute decision. Stevil never personally crossed any moral event horizon, did he?