Well, seeing as how he keeps reverting back to his original form after each attack, I don't think it will be much of a problem. I also assumed that he would only be taken over by the curse seal...which has no actual connection to Orochimaru. In other words, he would become a mindless demon, not an Orochimaru supporter. I wonder if Juugo needs to worry about being taken over by the curse seal, however. It was originally his technique alone.