Yes, but well before that Michael tells Vincent that the price he has to pay for power is to give up Mary. Michael didn't have to do that. He held the power. It was his to give away or keep. Giving it away makes him a facilitator. But even before that he tries to exculpate himself by saying that "they pull me back in." In his conversation with Gilday, he is participating in extortion, something else he doesn't have to do. His machinations in Sicily are hardly those of someone giving up anything. He tells Vincent that he is now a Corleone. I think that all screams accessory before the fact.