What happens when a famous basketball player travels to a totalitarian prison state to sing Happy Birthday to a tyrant? He gets a lot of criticism … and attention, of course. What happens when he brings some expensive birthday gifts? Dennis Rodman might just get prison time:

On his third and most recent trip to Pyongyang this month, Rodman reportedly brought several gifts for the young Kim’s 31st birthday. They allegedly included hundreds of dollars’ worth of Irish Jameson whiskey, European crystal, an Italian suit, a fur coat, and an English Mulberry handbag for Kim’s wife, Ri Sol-ju.

But these gifts, reportedly worth more than $10,000, may not have been all. Michael Spavor, a Beijing-based consultant who facilitated and joined Rodman’s triptweeted a photo of Rodman apparently displaying several bottles of his own brand “Bad Ass Vodka” for Kim Jong Un and his wife.

These gifts could be more than tasteless. They could also put Rodman in legal jeopardy. They appear to be violations of United Nations Security Council Resolutions 1718, adopted in 2006, and UNSCR 2094, adopted in 2013.

Perhaps more importantly, Rodman may have violated an American law called the International Emergency Economic Powers Act (IEEPA), as implemented byExecutive Order 13551, which President Obama signed in 2010, which makes it a violation of U.S. law for any person determined by the Treasury and State Departments “to have, directly or indirectly, imported, exported, or reexported luxury goods to or into North Korea.”

This isn’t just a customs fine, either. The civil penalties, Josh Rogin explains, could be $250,000 per violation. If pursued as a criminal matter, the fine could go as high as one million dollars — and 20 years in prison. That’s an awful lot of hard time for some awful “Bad Ass Vodka,” and perhaps the most awful photo op in recent memory. And Rogin, who should be read in full, thinks that Treasury will have a good case against Rodman if it chooses to pursue it.

Rodman won’t be able to respond immediately to the story, because he checked into rehab when he came back to the US after his visit to his good friend Kim Jong-un. His agent later said that Rodman was “embarrassed, saddened and remorseful for the anger and hurt his words have caused,” referring to when Rodman implied that American hostage Kenneth Bae — for whom Rodman publicly refused to lift a finger while in North Korea — was a criminal who deserved his detention. Expect more protestations of his embarrassment and remorse for these alleged violations of export laws and sanctions meant to keep a nuclear power from going off the rails.

However, I doubt that this will result in criminal prosecution. Civil fines will almost certainly follow if Rodman’s actions are shown to have violated the law, and they’ll probably be steep enough to keep him from offering “Bad Ass Vodka” to any more dictators in the future. I just don’t see Treasury going after Rodman with criminal charges all the way to a trial, even though they should if he broke the law, but they may use some to leverage a settlement on civil charges in the end.

How do you think Treasury should deal with Rodman, under the assumption that the charges are true and provable? Take the poll: