This is actually super super tricky.

So, there's an exemption for 'Transformative' art, and while this is obviously pretty shady, it feels like there's a good chance this would qualify as transformative. Basically, you can't copy an existing photograph you don't own, but you can take an existing person and paint a new original picture of them.

We had a big lawsuit just last year where the Supreme Court clarified the line a bit. In that case, the art was found to be not Transformative, but they did a lot to explain why, and based on that, this would be super likely to fall on the side of 'Legally Allowed'.