Chameleon Carriers, Fraud Detection, and FMCSA’s Evolving Data Strategy

Chameleon carriers—trucking companies that shut down and quickly reopen under new identities to avoid regulatory enforcement—have posed a persistent challenge for federal regulators for more than a decade. These operators, often emerging with new names, DOT numbers, or corporate structures, can be difficult to distinguish from legitimate new entrants simply trying to begin operations. Yet the stakes are high. Reincarnated carriers have historically shown higher crash rates, and their ability to hide prior compliance issues undermines both safety oversight and fair competition.

To confront this problem, FMCSA has experimented with several data-driven approaches over the years. One of the most significant early efforts was ARCHI, short for Application Review and Chameleon Investigation, a prototype vetting system developed after congressional direction in 2012. Recently, however, a newly surfaced internal memorandum from the U.S. Department of Transportation—dated November 12, 2025—suggests a renewed push to leverage a risk-based, data-driven severity matrix focused on behaviors associated with identity-related fraud. 

The overlap between the memo’s proposed methodology and the approach FMCSA described in 2013 raises important questions about how the agency’s strategy has evolved (if at all), what tools remain in use, and what the future of chameleon-carrier detection might look like.

This article offers a detailed examination of those themes—looking at where the federal effort started, how the problem has changed, and what the leaked memo may signal about the way forward.

How Chameleon Carrier Fraud Emerged as a Priority

The late 2000s brought national attention to carriers that appeared to have evaded enforcement by shifting identities. A series of high-profile crashes involving passenger and freight carriers prompted investigations revealing that some operators had histories of violations, penalties, or failed inspections under prior names. These revelations raised concerns that FMCSA’s registration processes were not catching reincarnated carriers early enough, or at all.

The Government Accountability Office (GAO) analyzed this issue in 2012, concluding that while FMCSA had a formal vetting program, it applied almost exclusively to passenger carriers and household-goods movers. Freight carriers—by far the largest category of new applicants—were largely unexamined. In response, Congress directed FMCSA to develop a risk-based methodology to screen all applicants, not just a select few.

FMCSA’s 2013 Report to Congress described the agency’s solution: a new analytical screening model built around match criteria (to evaluate similarity between entities) and motive criteria (to evaluate whether a past entity had reasons to reenter the industry under a different identity). This marked the beginning of the ARCHI system. 

FMCSA’s First Large-Scale Attempt at Automated Vetting

ARCHI was conceived as a prototype built in collaboration with PHMSA, leveraging the capabilities of the Hazmat Intelligence Portal for data storage and analysis and is still in use today. The system’s core function is relatively straightforward: compare the attributes of a new applicant against those of existing or previously operating carriers, and determine whether the similarities warrant closer scrutiny. But ARCHI’s design goes deeper, incorporating multiple layers of analysis.

ARCHI begins by calculating a “match score” across several key identifiers, including:

• Company and officer names

• Physical and mailing addresses

• Phone numbers

• Tax identifiers such as EINs

• Indicators like Social Security numbers or DUNS numbers (where available)

• Other fields available in FMCSA’s Licensing & Insurance system

The system assigns numerical weight to different elements, with certain data points—like EINs or SSNs—carrying greater significance than others such as phone numbers or addresses. A score of 1.5 or greater indicates a possible identity match between the applicant and a known carrier. 

ARCHI then evaluates whether the matched entity has factors that might naturally incentivize reincarnation, including:

• Prior unsatisfactory or unfit safety ratings

• Recent involvement in serious crashes

• Out-of-service or imminent hazard orders

• Bankruptcies or financial distress

• Civil penalties or other enforcement actions

Where both match and motive are present, the application is flagged for manual review.

The 2013 report outlines FMCSA’s intention to:

• Continue refining ARCHI through pilot studies

• Expand data sources beyond FMCSA systems

• Conduct sensitivity analyses to evaluate false positives and false negatives

• Ultimately integrate ARCHI into the Unified Registration System (URS)

In other words, ARCHI was never intended to remain a prototype—it was meant to become part of a comprehensive, automated vetting workflow. Resource constraints, however, were a consistent caveat in the report, particularly regarding IT modernization and legal resources needed for final authority decisions. 

FMCSA Pursuing New Risk-Based Approach?

The leaked memo—drafted by the Director of Strategic Initiatives in DOT’s Office of the Assistant Secretary for Research and Technology—describes a renewed effort to address chameleon-carrier fraud using a “data-driven severity matrix.” The memo cites a review of SAFER and registration data that identified patterns consistent with operators attempting to disguise their identity. Among the indicators:

• Shared addresses and contact information among multiple entities

• Rapid turnover of DOT numbers

• Clusters of newly formed companies in particular commercial corridors

• Equipment reported under multiple carriers

• Inconsistencies in fleet reporting or registration activity

The memo frames these indicators as part of a coordinated pattern used to evade scrutiny, and proposes assigning severity “scores” to carriers across the industry based on the presence of such behaviors. The goal is to allow DOT and FMCSA to intervene earlier, focusing attention on carriers whose data footprint suggests elevated risk. 

Although the memo does not mention ARCHI, the conceptual similarities are obvious—particularly the emphasis on data-driven pattern recognition, abnormal operational indicators, and risk scoring.

While the two documents were written twelve years apart, their underlying analytical approaches align in several key respects:

1. Both rely on automated screening to detect identity overlap. ARCHI uses matching algorithms; the new memo proposes a severity matrix built on behavioral indicators.

2. Both view certain patterns—shared addresses, repeated contact information, inconsistent fleet records—as signals worth closer attention.

3. Both emphasize the need for efficient resource allocation. Given FMCSA’s limited capacity to manually vet every applicant, risk-based screening remains essential.

4. Both anticipate integration with broader registration systems. ARCHI was designed to feed into URS; the memo focuses on closing “systemic weaknesses” in registration oversight.

What differs primarily is the framing. ARCHI was born from a specific congressional mandate tied to improving vetting. The memo appears forward-looking, proposing enhancements to existing oversight structures without explicitly referencing the legacy systems from which they may draw.

Why the Problem Persists Despite Past Efforts

Even with tools like ARCHI, chameleon carriers remain a recurring point of concern. Data quality varies widely depending on how applicants complete forms, and some identifiers—such as DUNS numbers—are not uniformly provided. The sheer volume of applications makes manual review impractical without strong automated tools. Meanwhile, would-be fraudulent actors modify their tactics over time, learning how to avoid obvious matches. And perhaps most significantly, the full implementation of FMCSA’s Unified Registration System has experienced multi-year delays, complicating the agency’s ability to integrate modern vetting capabilities into a single, consolidated workflow. Taken together, these factors make clear that combating reincarnated carriers is not a one-time systems project but a continuously evolving challenge.

While FMCSA’s approaches have developed over time, private industry has also taken an active role in addressing identity-related fraud. Several technology companies have built proprietary systems designed to flag chameleon-like behavior, often using datasets or analytics beyond what FMCSA makes publicly available. Tools like DAT’s Alias Search, for example, combine historical address and contact information to identify linkages between carriers. Others, such as Genlogs, incorporate operational telemetry to validate whether carriers operate where and how they claim.

The emergence of these tools reflects two complementary realities: stakeholders have a strong interest in avoiding high-risk carriers, and private entities are often able to innovate more quickly than federal systems constrained by appropriations cycles and regulatory processes.

USDOT’s leaked memo should be read not as a final policy but as a snapshot of DOT’s internal thinking. It suggests a desire to modernize existing vetting processes and to apply a more holistic data-driven approach across the entire carrier population. It also reflects a recognition that some operators continue to exploit gaps in the current system, and that improved analytics are necessary to stay ahead of those behaviors. The memo’s proposal to use a severity matrix—assigning a risk score that reflects multiple behavioral dimensions—fits within a broader trend across the federal government toward data fusion, pattern recognition, and predictive indicators. In this sense, the memo seems less a departure from FMCSA’s historical work on chameleon carriers than an extension of the core principles behind ARCHI, adapted to a 2025 data environment.

Moving Forward

If FMCSA pursues a severity matrix or moves to modernize ARCHI’s conceptual framework, success will likely depend on several factors.Integrating disparate data sources—registration records, safety history, enforcement actions, corporate filings, and commercially available intelligence—could significantly enhance accuracy. Improvements in machine learning and adaptive algorithms may help identify emerging reincarnation patterns without pre-set scoring logic. And increased transparency around metrics such as false-positive rates, flagged-application outcomes, and observed safety impacts would support trust among carriers, insurers, and the public.

In addition, any vetting tool must align with FMCSA’s enforcement authority under 49 CFR 386.73, which provides standardized criteria for identifying reincarnated or affiliated carriers during enforcement proceedings. The closer the connection between upfront vetting and downstream enforcement, the more consistent and effective the overall system will be.

Chameleon-carrier fraud continues to present safety risks, regulatory challenges, and economic consequences across the trucking industry. FMCSA’s early efforts, documented through ARCHI and related initiatives, reflected a strong push to address these risks through analytical screening tools and risk-based methodologies. The newly surfaced 2025 memo signals that this effort is ongoing, and that the federal government remains committed to refining its approach.

Whether the next phase involves enhancing existing systems, building new ones, or integrating both into a modernized URS platform, the core objective is unchanged: to identify operators attempting to obscure their identity and ensure a level playing field for carriers committed to safe, compliant operations.

The methods and technologies may evolve, but the goal remains fundamentally the same—and the trucking industry has a strong stake in seeing that goal achieved effectively.

About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a livestream podcast on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who've assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube. Or subscribe to Trucksafe's newsletter for the latest highway transportation news & analysis. Also, be sure to check out eRegs, the first app-based digital version of the federal safety regulations aimed at helping carriers and drivers better understand and comply with the regulations.