Franchise newcomer Bruhl has admitted to The Business Insider that new villain Baron Zemo is not going to be a pure adaptation of the source (basically the entire approach to Civil War, then) and that he won't be wearing the iconic purple mask:
"You would be surprised, its different than what youd think. Its loosely connected to this character. But thats what I like about the Marvel guys, some of the characters and things theyre dealing with always reference to current events so my character is from a different area than you would think."
So it's likely best to think of Zemo as an entirely different entity - but then there must be a reason he's called Zemo (other than bran recognition), right? While it's unlikely he'll be starting any Masters Of Evil ensemble in Civil War, he might well be behind the capture of Bucky that lures Cap and Falcon (and Ant-Man) to the HYDRA base we saw at the end of Ant-Man. That would fit the character's history in the comics. Quite how Zemo is going to reference current events remains to be seen. Rating: 10/10 While it's a shame that the mask won't be involved, casting someone like Daniel Bruhl and then putting him completely under cover would have been an odd decision. And in a political environment of duplicity, where nobody is quite who they seem, manipulating evil schemes in plain sight, having someone walking around in such ostentatious an outfit would be a mistake too. So it's definitely more likely we'll see Zemo as a modernised, toned down villain.