I'm not quite sure about this one. I think that the current design on the reverse is an issue. But the front doesn't seem to break any laws.

I'm assuming they print these under subsection Y of 31 U.S. Code § 5112 - Denominations, specifications, and design of coins. Which pertains to these 250th anniversary coins.

The part I see mentioned in this thread frequently applies to a separate subsection (n) for a run of $1 presidential coins that has since ended.

If you just read subsection Y in a vacuum, they are good to go. This part at the bottom though says that the reverse can't be a 'portrait'.

So this isn't really slam dunk illegal, but I don't think that the draft of the coins reverse will make it to print. I would fully expect the front to come out just like that though based on my interpretation.

(aa)Standards and General Provisions for Circulating Collectible Coins Under Subsections (x), (y), and (z).—

(1)Prohibition on certain representations.—

No head and shoulders portrait or bust of any person, living or dead, and no portrait of a living person may be included in the design on the reverse of any coin under subsections (x), (y), and (z).