At least four lobbyists who are involved in the Donald Trump transition or who are being considered for a Cabinet-level position have filed paperwork in the past week and a half to terminate their status as federal lobbyists — an apparent move to comply with the president-elect’s new ban on lobbyists in the administration and transition.

Jeffrey Holmstead, an energy lobbyist and lawyer at Bracewell, the former law firm of Trump surrogate Rudolph W. Giuliani, filed disclosure forms on Nov. 18 to end his representation of Ameren, DTE Energy, Duke Energy and several other energy and utility companies. Holmstead, who was an assistant administrator at the Environmental Protection Agency under President George W. Bush, is being considered for EPA administrator.

The filing came two days after Trump’s transition team announced that registered lobbyists will not be allowed to serve in the new administration and that lobbyists would no longer be involved in the transition process. As part of the new policy, every person who joins the administration will be asked to sign a form that states they are not a registered lobbyist. If they are, they will have to provide evidence of their termination. Holmstead’s filing is a sign that he may soon be taking a role in the administration. He could not be reached for comment.

Three lobbyists involved in the transition — who work on policy and on the “landing teams” — recently deregistered as well, according to lobbying disclosure filings. Landing teams are the groups meeting with Obama administration officials on behalf of the transition to manage the handoff of federal agencies.

Jim Carter, a lobbyist at the manufacturing company Emerson overseeing tax reform for the transition, filed a termination report on Nov. 21.

Mauricio Claver-Carone, a lobbyist who led the U.S.-Cuba Democracy PAC — which supports the U.S. embargo unless Cuba undergoes democratic reforms — filed a termination report on Nov. 18. He was named to the Treasury Department landing team on Nov. 21.

David Bernhardt, who is leading the transition’s Interior Department issues, filed a termination report on Nov. 18. Bernhardt is a partner at the law-and-lobby firm Brownstein Hyatt Farber Schreck and lobbied for the Westlands Water District.

They did not immediately respond to requests for comment.

The filings — known as “deregistering” — allow the lobbyists to technically comply with the lobbyist ban but violates the spirit of the ban, which is ostensibly meant to prevent conflicts of interest from influencing government officials’ decision-making. Ethics experts also have noted that although Trump has addressed lobbyists’ conflicts, he has yet to do so for people with other financial conflicts of interest, such as corporate executives who have been heavily involved in the transition and are being considered for administration appointments.

“This kind of snap immunity demonstrates the flaw in the apparent Trump approach focusing on lobbying conflicts to the exclusion of other kinds,” said Norm Eisen, chief White House ethics lawyer in the Obama administration. “There are also a huge amount of non-lobbying conflicts both coming into and leaving a transition … that Trump’s emerging ethics structure does not seem to adequately address.”

A Trump spokeswoman did not respond to a request for comment.

Brady Dennis contributed to this report.