Robin Raphel has been hired by the State Department, but may either be exempt from the administration's new revolving door rules or require a waiver. Raphel was a senior vice president for Cassidy and Associates since 2007. This case may point out a loop hole in the new lobbying rules. According to The Hill, "Raphel's appointment could conflict with the order since she lobbied State and also was a foreign agent for Pakistan, albeit briefly, during the two years prior to her apartment." If she is not exempt, she could receive a waiver.

Raphel, however, might be exempted from the ban already. The order specifically exempts "any person appointed as a member of the Senior Foreign Service or solely as a uniformed service commissioned officer," according to the order. Raphel's appointment as coordinator of U.S. non-military assistance to Pakistan may rank high enough to be part of the Senior Foreign Service, a class of foreign-service officer comparable to high-ranking military generals. Raphel's position could also not be a political appointment, which likewise would exempt her from the ban.