I know that Steve Kenson has said that Determination is for heroes only. And in general I'm against the idea of a villains campaign. Morally ambiguous, sure, but out and out villains...? Even though there have been good villain things (like Necessary Evil), they tend to be about bad guys being forced to be good guys.
And this weekend I read the first volume of Gail Simone's Secret Six. And a bunch of more broken but still functioning individuals will be hard for you to find. I immediately thought of doing it as a roleplaying campaign, with a similar setup: All the bad guys are forming a coalition. You don't want to. That puts you in their bad books.
Trivial to do in Hero, but I haven't run Hero for a long time. You could do it in Mutants & Masterminds but there's be fluctuating power levels to contend with. You could do it in Marvel Heroic Roleplaying but my guys don't like MHR. Savage Worlds, of course, but I don't have the super powers supplement.
And then I circled back to ICONS, even though I'd dismissed it. Because Steve said that bad guys don't have Determination; he didn't say that they can't get Advantages or Trouble.
So if you were going to use ICONS for a villain campaign, you just don't give them Determination. Any time they need an Advantage, the players have to use a Maneuver or a Tactic.
I haen't thought about how that would affect a campaign, but I'm willing to accept suggestions.
It's something to think about, anyway.