"Russian territory"

I'm sure no one but geography nerds like me noticed, but when the New York Times writes that Syria is the "host to its one major naval facility outside Russian territory", the Times is implicitly recognizing the Russian annexation of Crimea.

ADDING: Actually, I just noticed that in the dead tree edition of the Times the sentence I quoted ends with "outside Russia", whereas the online version of the article I linked to above says "outside Russian territory." Maybe "Russian territory" can be construed to include territory that it leases from another country like Ukraine. In other words, maybe the sentence was revised to address this very concern. On the other hand, Russia is not currently paying rent to Ukraine for its Sevastopol base, so I don't think you can weasel out of the implicit recognition by claiming that it is Russian territory through a rental arrangement.

On the third hand, I'm probably giving this a bit more thought than it's worth.