Inside FMCSA's ARCHI System and the War on Chameleon Carriers

How the FMCSA has attempted to transform from a reactive regulator to a proactive hunter, and has it worked?

In the aftermath of the 2008 Sherman, Texas bus crash and Kelly Linhart's death, the fed Motor Carrier Safety Administration faced the reality that dangerous carriers were gaming the system with impunity, shutting down operations only to reopen under new names while keeping the same unsafe drivers and equipment. The agency's response would fundamentally transform how America vets commercial carriers, creating one of the most sophisticated risk-based screening systems in fed transportation regulation.

Today, every new carrier application faces scrutiny from ARCHI - the Application Review and Chameleon Investigation system, a cutting-edge algorithm that can connect dots human investigators might miss. This is the story of how FMCSA evolved from checking just 2 percent of new applicants to comprehensive automated screening, and the ongoing battle to stay ahead of increasingly sophisticated chameleon carriers.

The Pre-2008 System

Before the tragedies, FMCSA's vetting capabilities were woefully inadequate for the scale of the problem. The agency's vetting program was limited to bus companies (passenger carriers) and household goods movers, accounting for just 2 percent of all new applicants in 2010, as they were selected because they present the highest consumer protection and safety risks.

The remaining 98 percent of applicants, freight carriers most likely to be involved in fatal crashes, faced minimal scrutiny. The new entrant safety assurance program included questions about connections between new and previous carriers, but auditors lacked the guidance on how to interpret responses to distinguish chameleon carriers from legitimate carriers.

This system failure became tragically apparent in cases like Hester Inc., which showd just how easily dangerous operators could slip through regulatory cracks.

The Hester Case and System Failure in Real Time

In 2010, Hester Inc. was put out of service for failing a compliance review. The company president signed a new operating application for a different carrier, stating he had no previous association with any motor carrier. His deception went undetected under the existing system.

Days before Hester Inc. was scheduled to be shut down by the FMCSA due to an unsatisfactory safety rating, Scott Hester, the company's president, had already listed himself as the president of FTS Fleet Services. Despite the requirements of fed regs, FMCSA never made the connection between the companies until questioned by a reporter.

By June 10, five days after Hester Inc. had been ordered closed due to its unsatisfactory safety record, former Hester trucks and drivers were on the road as FTS Fleet Services. The case highlighted how carriers could easily go undetected because of heavy application loads and a lack of information sharing between agency divisions.

ARCHI System From Concept to Algorithm

Following the 2012 GAO report, Congress allocated an extra $3.5 million in 2012 for FMCSA to develop the new system and hire up to three additional staff. The agency began developing specifications for modifying its information technology systems for expanded vetting.

Through a Small Business Innovative Research (SBIR) Phase I project concluded in August 2014, FMCSA studied various methodologies for identifying likely high-risk carriers and tools to assist the agency's Vetting Team. The study examined approaches for developing proprietary risk-based screening processes utilizing available data from safety management sources.

The SBIR award included the production of the URSA (Utility for Risk-based Screening and Assessment) tool, which featured an algorithm and corresponding software for automatic risk-based assessment. This tool calculated risk potential based on the likelihood that an applicant was a chameleon carrier, attempting to reincarnate, or attempting to receive authority illicitly.

The FMCSA partnered with the Pipeline and Hazardous Materials Safety Administration (PHMSA) to utilize their web-based interface, which contains necessary data warehousing capabilities, known as the Hazmat Intelligence Portal (HIP). The prototype screening methodology can be run in the HIP environment during the development and testing phases.

How ARCHI Works

ARCHI (Application Review and Chameleon Investigation) uses information from FMCSA's Licensing and Insurance database to screen new carrier applicants using all available data fields to spot chameleons, including address, phone number, applicant name, employer identification number and more.

The process first compares each new carrier to older carriers for similarities in name, ownership, and other criteria. Each new carrier gets a score based on how closely it matches older businesses. Those who score above a certain cut-off are then evaluated for motive.

ARCHI's algorithm considers whether the prior carrier was in bankruptcy, was involved in a fatal or serious injury crash, was fined by FMCSA, ever issued an out-of-service order, or received an unsatisfactory safety fitness rating.

The system examines:

• Business names and variations

• Physical addresses and mailing addresses

• Phone numbers and fax numbers

• fed Employer Identification Numbers

• Individual names of owners, officers, and key personnel

• Vehicle identification numbers

• Commercial relationships and contracts

The model utilizes data from both the FMCSA and PHMSA agencies, as well as Dun & Bradstreet, a commercial database. The prototype identifies carriers with the highest likelihood to reincarnate based on having more than one risk factor.

Program Results

Since the program's implementation in 2016, nearly 90,000 applicants have been screened, with approximately 8,000 flagged as potential chameleon carriers. While the FMCSA keeps exact rejection numbers confidential, officials describe the number as "substantial." The system dramatically expanded from the original 2 percent of applicants (buses and household goods) to cover all interstate freight carriers, with 98 percent of new applicants most likely to be involved in fatal crashes.

ARCHI was initially tested using data from known chameleon carriers and proved effective at flagging suspicious companies, although tests identified areas needing improvement. The system entered a multi-year process of study and improvement. Following implementation, FMCSA spent time analyzing data and quantifying false-negative and false-positive results to refine the system's accuracy.

One of the most documented examples of modern chameleon carrier detection involves Specialized Solutions, a Lansing, Michigan-based trucking company that became the subject of investigative reporting by WOOD TV. Specialized Solutions operated 37 trucks and employed 21 drivers, covering a total of 3.8 million miles in 2016. The DOT cited the company with enough violations to earn an "unsatisfactory" rating, including falsifying logbooks, failing to keep minimum records of inspection and vehicle maintenance, and using drivers before receiving negative drug test results.

The Investigation revealed that the company's owner had previously operated Azda Logistics. This trucking company appeared to be a chameleon carrier for at least four other companies, three of which had been put out of service.

fed records showed the owner, Anvar Akhmedov, had a "history of non-compliance" beyond Specialized Solutions. Inspectors linked him to at least four other trucking companies. A compliance review noted that "Azda Logistics LLC with Anvar Akhmedov as the owner, manager or company representative appears to be a reincarnated carrier from at least four other motor carriers, three of which have been put out of service."

A 2016 compliance review predicted that "Azda Logistics will most likely reincarnate itself as Specialized Solutions LLC to avoid an adverse safety rating or history, a prediction that proved accurate. Despite this clear pattern, FMCSA officials ultimately found "no evidence" to support a charge that Akhmedov reincarnated carriers specifically to evade regs, noting that prior carriers had paid penalties and had "no unsafe current histories."

The owner admitted to Target 8 investigators that he had switched company names in the past to hide his troubled safety record from potential customers, but not from government regulators. When filing paperwork to open Specialized Solutions in 2014, Akhmedov did not list his other companies and checked "no" when asked if he was affiliated with other FMCSA-licensed carriers.

According to Michigan State Corp filings and records, as of today, Specialized Solutions, LLC is listed as active and not in good standing with an address of 2810 Canal Rd, Lansing, Michigan, with the owner listed as Anvar Akhmedov. It also lists a Nextgen Heavy Haul with an Active DOT number of 4070240, with the owner also being Anvar Akhmedov. Anvar’s LinkedIn profile does not mention owning or working for Specialized, but it does list previous employment with Azda as an Accountant. Today Nextgen operates with a vehicle OOS rate well above the national average at 42% and a driver OOS rate above the national average at 8% and that's with only being in business since 2023. Not even two years.

Anvar F Akhmedov is listed as the owner of Toro Trans with Michigan Corp records but under DOT number 3160601 with FMCSA data the owner’s middle initial is an A not an F. While in the Landing MI area and with a different address, and adding the middle initial makes it challenging to determine if this is the same Anvar Akhmedov, it is not uncommon for chameleon carriers to use other family member names or to add initials to their own name in filings. Maybe our research will turn up a VIN crossover we will see but you get the point.

This case has exposed and continues to expose the ongoing issues in enforcing chameleon carrier regulations. As a result of a 2010 FMCSA Assistant Administrator decision, it remains unclear whether FMCSA should use state or fed legal standards to show that a carrier is a chameleon. Evidence must be gathered to meet both standards, resulting in differing enforcement actions across states and increased time required for cases.

The FMCSA initially fined Specialized Solutions $29,690 for violations but later reduced the penalty to $14,845 as part of a settlement agreement. As a condition, the FMCSA agreed to monitor Specialized Solutions for a period of two years. The FMCSA expressed confidence that "if this same carrier attempted to apply for operating authority as a new carrier, the vetting technology would detect the relationships and flag them for further review."

System Effectiveness

The ARCHI system has showd significant improvements over pre-2008 capabilities. Using the data, FMCSA can more easily identify dangerous companies and shut them down. Insurers are also utilizing the data, enabling them to determine whether a new carrier is operating illegally or poses a significant safety risk.

FMCSA does not determine the total number of chameleon carriers within the motor carrier industry. Such a determination would require investigating each of the tens of thousands of new applicants who register annually and completing legal processes for suspected chameleon carriers, an effort for which the FMCSA lacks sufficient resources.

Other constraints on FMCSA enforcement actions include a resource-intensive legal process, inability to preclude carriers from obtaining multiple registration numbers, and low maximum fines.

Individuals caught operating reincarnated businesses do not always obey subsequent disciplinary action and can either ignore orders or simply start yet another chameleon operation. In such cases, individuals have faced prison sentences.

One attorney reported handling a case where "a family was repeatedly forced to close down their trucking companies for failure to conduct random drug tests, as required by fed regulation. They formed a total of 13 different companies before I took the case to trial in which one of their drivers was high on crystal meth and killed another truck driver".

Industry Integration and Private Sector Tools

The ARCHI system's data has found applications beyond fed enforcement. Private sector companies have developed complementary tools to help shippers and brokers identify potential chameleon carriers. Freight Validate is a good resource, as is SearchCarriers.com, but Genlogs is using tactics similar to how the CIA tracks terrorists in some cases. Using sensors across the US Genlogs is actually tracking trucks and where they have been seen, if they've ever been seen, on what lanes, and so much more data to really drill down on carrier fleets operating under the radar and off the grid. The private sector has more capabilities in many ways to combat this than the feds do, and it has invested more money in it than the feds have.

DAT developed the Alias Search, a free tool that allows users to see if an address, phone number, or fax number has been used previously by a carrier put out of business. This database combines current FMCSA data with historical data no longer available to the public.

Having results in Alias Search is not an indictment of a carrier, but an indication that further exploration may be necessary. The tool asks whether the same phone number was used by another carrier that was put out of service.

Insurance Industry Applications

Insurers are making use of ARCHI data, allowing them to determine whether a new carrier is operating illegally or poses a safety risk on the road. This has helped legitimate trucking companies by reducing the impact of chameleon carriers on overall industry insurance premiums.

Senator Charles Schumer sent a letter to the FMCSA instructing the agency to take further action to stop chameleon carriers, specifically requesting that the agency review driver safety records when a carrier applies for authority.

Schumer urged FMCSA to include information about individual drivers in the screening algorithm, noting that "chameleon carriers often re-form with the same management, same dangerous vehicles, same unfit drivers, and same unsafe ways".

FMCSA spokesperson Marissa Padilla said the agency has "taken aggressive steps" in recent years to better vet new entrant carriers and increased fines for carriers who reincarnate under new names. She also noted the agency's 2014 rule that expands authority to shut down carriers with a history of intentionally violating fed safety rules.

As of October 1, 2012, when the MAP-21 Highway Bill took effect, it became illegal to close down a failed trucking operation and start over with a new Motor Carrier number. DOT can revoke registration or authority of a reincarnated carrier or levy fines.

MAP-21 also requires carriers, brokers and freight forwarders to "disclose any relationship through common ownership, common management, common control or common familial relationship to any other motor carrier, broker or freight forwarder".

Despite enhanced legal authority, enforcement remains tough due to the burden of proof required and sophisticated evasion tactics employed by persistent offenders.The FMCSA continues to develop the model in conjunction with designing the Unified Registration System, which will replace the current systems used to track carriers. Over time, the agency conducts validation studies of the model to enhance its accuracy. The relationship between FMCSA and chameleon carriers has evolved into a technological arms race. As detection methods improve, bad actors adapt their concealment strategies, requiring constant system evolution.

The ARCHI system is just one component of FMCSA's broader safety oversight transformation, working alongside the Compliance, Safety, Accountability (CSA) program and enhanced roadside inspection protocols.

The enhanced screening is "particularly good news for trucking companies that are safe, legitimate, and compliant with regs. Chameleon carriers are statistically more dangerous on the roads, and their unsafe operations can impact overall insurance premiums for all trucking companies".

Most shippers and 3PLs are practicing strict and thorough carrier vetting procedures nowadays. Implementing and following thorough processes for carrier screening is the only way to ensure dispatching freight into good hands. The ARCHI system has contributed to a broader cultural shift in how the transportation industry approaches carrier vetting, moving from reactive responses to proactive risk assessment.

Chameleon carriers are three times more likely to be in a crash involving serious injury or fatality compared with other new applicant carriers. According to the U.S. Government Accountability Office, chameleon carrier drivers collectively were responsible for 3,561 injuries and 217 deaths from 2005 to 2010. The FMCSA hasn't designed a fool-proof process of catching chameleon carriers. Even though vetting new trucking companies for "chameleon attributes" can help identify some chameleon carriers, it's still difficult to filter all "new" trucking companies with poor safety records.

The ARCHI system is a remarkable transformation in fed reg capability, evolving from a system that checked just 2 percent of applicants to comprehensive automated screening using sophisticated algorithms but cases like Specialized Solutions show that technology alone cannot solve the chameleon carrier problem.

Success requires a combination of advanced detection algorithms, adequate legal authority, sufficient resources for enforcement, and industry cooperation. The system has undoubtedly prevented dangerous carriers from easily obtaining new operating authority, but persistent offenders continue to find ways to game the system.

As detection methods improve, evasion tactics evolve. The ARCHI system represents the current state of this technological arms race, but the battle for safer highways requires constant vigilance and adaptation.

Behind every algorithm and database query lies the human cost that drove this transformation. The 17 Vietnamese Catholics who died near Sherman, Texas, and Kelly Linhart, struck down during a routine inspection, represent the stakes in this ongoing battle. Their deaths catalyzed the most comprehensive regulatory response to chameleon carriers in transportation history.

The ARCHI system stands as a technological monument to their memory and a commitment that their deaths would drive meaningful change. While the system is not perfect, it represents a dramatic improvement over the regulatory sieve that existed before 2008.

As the transportation industry continues to change, the challenge of staying ahead of chameleon carriers is a constant. The ARCHI system provides the foundation for this effort. Still, the ultimate success depends on continued investment, legal support, and industry cooperation in the shared goal of safer highways for all Americans. If Elon taught us anything, it is that private industry can help if we let it.