The Same Door, Both Ways: Who Regulates Autonomous Vehicles

August 2026

An earlier brief in this library, Follow the Autonomous Money Trail, tracked how money moves toward autonomous vehicle (AV) deployment through venture capital, federal lobbying, political action committee contributions, and defense contracts. It closed on a list of people: a former Administrator of the Federal Motor Carrier Safety Administration (FMCSA), a former Acting Deputy Administrator, a former Chief Counsel, a former Chairman of the American Association of Motor Vehicle Administrators, and two former Chairs of the American Trucking Associations board, all now working for or advising the companies seeking federal authority to run trucks without drivers.

That list ran one direction. Regulators leaving government for industry.

This brief covers the other direction. People who came out of the AV industry and into the federal positions that now write, enforce, or fund the rules governing it. The scope is the U.S. Department of Transportation (DOT) and the Department of Defense, because AV money and AV rulemaking both run through the two of them.

Every position covered here was filled during 2025. Every financial figure comes from a filing the official signed under penalty of law, from the U.S. Office of Government Ethics (OGE), or from a federal agency’s own published record. Where a fact could not be confirmed, it is stated as unconfirmed rather than assumed.

One thing this brief does not do is draw a legal conclusion. Holding stock in a company is not a crime. Coming from an industry is not a crime. Federal conflict of interest law under 18 U.S.C. 208 turns on whether an official participated personally and substantially in a particular matter affecting a financial interest they held at the time. That determination belongs to the Office of Government Ethics, an agency inspector general, or a court. What follows is the timeline, the dollar figures, and the dates. The reader can decide what it adds up to.

Emil Michael, Under Secretary of Defense for Research and Engineering

Emil Michael was Chief Business Officer at Uber from 2013 to 2017. The U.S. Senate confirmed him on May 14, 2025 by a vote of 54 to 43 as Under Secretary of Defense for Research and Engineering, which carries the additional title of the department’s Chief Technology Officer. He was sworn in May 20, 2025. On August 26, 2025 he took on a second role as Acting Director of the Defense Innovation Unit (DIU), the Pentagon office that contracts with commercial technology companies. He held that acting role until March 2, 2026.

DIU is the office that awarded Kodiak Robotics a $49.9 million contract for the Army’s Robotic Combat Vehicle program and Applied Intuition a $171.1 million production contract through the Pentagon’s Chief Digital and Artificial Intelligence Office. Both contracts appear by name in Follow the Autonomous Money Trail.

The Uber position. Michael’s financial disclosure filed at nomination listed Uber Technologies stock valued at $50 million or more, producing capital gains income of $5 million or more. That is the largest single holding identified anywhere in this research, by roughly an order of magnitude. His disclosed transaction record shows Uber sales in June 2025, on November 26, 2025, and again on February 2, 2026. Whether those sales brought the position to zero could not be confirmed from public filings.

The xAI position. In March 2025, before joining the department, Michael declared a private investment in xAI, the artificial intelligence company behind the Grok product, valued between $500,000 and $1 million, held through a fund called KQ Partners. In July 2025 the Pentagon named Grok one of four commercial providers to support the department’s use of artificial intelligence. On December 18, 2025, roughly seven months into his tenure, OGE issued him a certificate of divestiture for the xAI holding. Four days later, on December 22, 2025, the department announced a further agreement with xAI. Michael sold the position on January 9, 2026 for between $5 million and $25 million. The Guardian reported the gain at up to $24 million.

The autonomous vehicle overlap. As Acting DIU Director, Michael announced the Autonomous Vehicle Orchestrator Prize Challenge, with up to $100 million available in awards and a submission window closing January 25, 2026. He is quoted by name in the DIU release announcing it. That window sits inside the same stretch as his January 9 xAI sale and closes one week before his February 2 Uber sale.

Senator Elizabeth Warren wrote to Michael on March 2, 2025, before his confirmation, raising conflict of interest concerns about his relationships with technology companies seeking Defense Department contracts and asking him to commit to recusals. A Defense Department spokesperson has said Michael is in full compliance with all ethics laws and regulations and that claims otherwise are false.

Peter Simshauser, Chief Counsel, National Highway Traffic Safety Administration

The National Highway Traffic Safety Administration (NHTSA) writes the Federal Motor Vehicle Safety Standards. On autonomous vehicles specifically, it is the agency with the pen.

Peter Simshauser joined NHTSA as Chief Counsel in January 2025. From March 2020 to August 2024 he was Chief Legal Officer and Chief Compliance Officer at Motional AD Inc., the Hyundai and Aptiv joint venture that builds and operates driverless vehicles commercially. NHTSA’s own biography of him describes that work as leading the legal compliance and government affairs teams to secure approvals to deploy Motional’s driverless vehicles on public roads. He negotiated with the agency he now advises.

Before Jonathan Morrison was confirmed as Administrator in September 2025, Simshauser served as NHTSA’s Acting Administrator.

The financial overlap. His disclosure lists Motional restricted stock units valued between $100,000 and $250,000, a Motional salary and bonus of $924,000, and severance paid twice monthly at $17,875 per payment running through February 2025. He joined NHTSA in January 2025. By his own filing, he was drawing severance income from an autonomous vehicle company while already serving as the agency’s Chief Counsel, for a period of roughly one to two months.

The regulatory actions. On April 24, 2025, DOT announced a new AV Framework built on removing regulatory barriers. NHTSA’s first two actions under that framework were announced in an open letter signed by Simshauser as Chief Counsel. Those actions cut back the Standing General Order requiring manufacturers and operators to report crashes involving Automated Driving Systems (ADS) and Advanced Driver Assistance Systems, and expanded the Automated Vehicles Exemption Program to domestically produced vehicles. He issued a second open letter continuing that work on June 13, 2025. In announcing the changes he said the agency was enabling AV manufacturers to develop faster and spend less time on unnecessary process.

Chief Counsel is not a Senate-confirmed position. The public ethics agreement and compliance certification process that applies to Senate-confirmed appointees does not appear to have produced a public document in his case. No ethics agreement or recusal terms naming Motional could be located.

Jonathan Morrison, Administrator, National Highway Traffic Safety Administration

The Senate confirmed Jonathan Morrison as NHTSA Administrator on September 18, 2025. He had served as the agency’s Chief Counsel from 2017 to 2021.

Between those two periods of federal service, two things appear on his disclosure. He worked as an attorney at Apple, Inc. from March 2021, leading legal, regulatory, government affairs, and policy for Apple’s Special Projects Group, which housed the company’s autonomous vehicle program. And from February 2022 to February 2024 he served as a Director of the Autonomous Vehicle Industry Association (AVIA), the trade association whose lobbying spending and regulatory recommendations are documented in Follow the Autonomous Money Trail.

Apple’s Special Projects Group, where Morrison led legal, regulatory, government affairs, and policy work, housed Project Titan, Apple’s self-driving car program. Titan ran roughly a decade, reportedly cost the company on the order of $10 billion, and at points employed close to 2,000 people, before Apple cancelled it in February 2024 and withdrew its California autonomous-testing permit that October.

His AVIA directorship ended the same month Apple’s self-driving car program, Project Titan, was cancelled — Bloomberg broke the cancellation on February 27, 2024. Apple’s disclosure gives only month-level precision for his board departure, so no exact-day relationship between the two events can be confirmed. Whether his AVIA departure was connected to Titan’s end or coincidental, the alignment is close enough to note.

The financial position. Apple salary and bonus of $451,000. Unvested Apple restricted stock units valued between $500,000 and $1 million. Apple stock valued between $500,000 and $1 million producing capital gains dividends between $15,001 and $50,000. An anticipated bonus under a retention agreement entered in August 2024, plus an anticipated severance payment, each valued between $50,001 and $100,000.

The non-disclosure agreement. At his July 16, 2025 confirmation hearing, Morrison confirmed he is subject to non-disclosure agreements with Apple. He confirmed he had not requested release from them and said he would work with the committee if confirmed, and would consult NHTSA’s designated ethics official before any engagement with Apple implications.

Two points cut the other way and belong here. His AVIA directorship ended in February 2024, more than a year before his nomination. And no periodic transaction report showing post-confirmation stock trading was found for him. Absence of a filing is not proof that no trading occurred, but nothing was found.

His signed ethics agreement could not be located, so what recusal commitments he made regarding Apple or AVIA is unknown.

Sean McMaster, Administrator, Federal Highway Administration

Sean McMaster was confirmed as Administrator of the Federal Highway Administration (FHWA) on September 18, 2025, the same day as Morrison, in the same en bloc vote. He came from Boeing, where he was Vice President for Commercial Aviation and Transportation, and before that spent 2019 to 2023 at HNTB Corporation, an infrastructure consulting firm.

His case runs differently from the others. What appears in his record is not a prior industry employer. It is trading activity while in office.

The purchases. On October 2025 he purchased Grab Holdings Limited stock valued between $15,001 and $50,000. From late December 2025 into early January 2026 he purchased additional Grab Holdings stock valued between $30,002 and $100,000. On January 9, 2026 he purchased up to $15,000 in Robinhood Markets. On January 13, 2026 he purchased up to $50,000 in One Stop Systems, a company that describes itself as a manufacturer of computer systems for defense, oil and gas, mining, autonomous vehicles, and rugged entertainment applications.

Why Grab Holdings matters. Grab is a Singapore-based company operating ride-hailing, taxi booking, and food delivery across Southeast Asia. On November 10, 2025 it announced a $60 million investment in Vay Technology GmbH, a remote driving technology company that has operated a commercial remote-driven vehicle fleet on public roads in Las Vegas since 2024. Vay’s teleoperation technology also supplies the remote-driving labor behind Kodiak Robotics’ autonomous truck fleet, the same company profiled in this library’s brief on remote assistance operators. McMaster’s stake in Vay’s parent investor sits upstream of both businesses. Grab’s option to invest a further $350 million in Vay is conditioned in part on the number of U.S. cities covered and on obtaining regulatory approvals to operate in additional U.S. cities. McMaster’s first Grab purchase predates that announcement. His second, larger purchase falls around or after the deal’s expected closing.

The Tesla divestiture. His April 4, 2025 ethics agreement committed him to divest his Tesla holding within 90 days of confirmation. His own periodic transaction report records a Tesla sale dated December 10, 2025, valued between $250,001 and $500,000, filed December 11, 2025.

His Certification of Ethics Agreement Compliance, signed December 12, 2025 and due December 24, records that he completed all required resignations and divestitures, that he has a managed account or uses an investment professional and notified them of the limitations in his ethics agreement, that he received no waiver under 18 U.S.C. 208 and no authorization under 5 C.F.R. 2635.502(d), and that the pre-government-service forfeiture provision did not apply to him.

No FHWA rulemaking, grant decision, or policy action naming Grab Holdings, One Stop Systems, or Robinhood was found. A Federal Highway Administration spokesperson has said McMaster is in full compliance with federal ethics requirements and that all financial disclosures are reviewed by career officials. A government watchdog organization has said the Grab investment gives at least the appearance of impropriety.

Steven Bradbury, Deputy Secretary of Transportation

Steven Bradbury was confirmed March 11, 2025 and sworn in March 13, 2025 as Deputy Secretary of Transportation. He oversees the department’s operating administrations, which includes FHWA, NHTSA, and FMCSA.

From December 2022 to March 2025 he was a Distinguished Fellow at the Heritage Foundation. He is credited as the author of Chapter 19 of Project 2025’s Mandate for Leadership, the chapter covering the Department of Transportation. The published document names him for special mention among the contributors to that chapter.

Follow the Autonomous Money Trail documented that AVIA’s regulatory recommendations to DOT echo language published in Project 2025 on rolling back the assumption that a commercial motor vehicle must have a human driver, and stated that connection as a matter of record between two documents rather than an inference. The person who wrote the transportation chapter now holds the department’s second-ranking position.

His financial disclosure shows no individual holdings in any autonomous vehicle, mobility, or transportation company. His holdings are index and mutual funds across a Roth individual retirement account and a rollover account. His outside income was a Heritage Foundation salary of $260,000 plus two honoraria, $5,000 from S&P Global and $1,000 from Capital Alpha Partners. His connection to this subject is authorship, not money.

Two cases that run clean

A brief that only reports what looks bad is not reporting. Two officials in the same set do not show the pattern above.

Derek Barrs, Administrator, FMCSA. Confirmed October 7, 2025. His financial disclosure lists two sources of compensation above $5,000: HNTB Corporation, at $437,000 salary, and the Flagler County District Schools board, at $19,550. His role as President of the Commercial Vehicle Safety Alliance (CVSA) Associate Membership from October 2022 to October 2024 is listed as uncompensated and ended before his nomination. No payment from AVIA or any AV developer appears. One item is unresolved: his Certification of Ethics Agreement Compliance carries a line under payments required to be completed before entering government service reading “09/24/2025 CVSA Annual Conference,” marked resolved. September 24, 2025 was the closing day of CVSA’s 2025 Annual Conference in Denver, during the window between his nomination and his confirmation. What that financial interest was is not stated in the certification and could not be determined.

Sean Duffy, Secretary of Transportation. His disclosure records a mass divestiture on February 11, 2025, selling Apple, DoorDash, Datadog, Shopify, DraftKings, and other individual holdings on a single date before taking office. On the specific question this brief examines, his record runs the opposite direction from the pattern above.

What the record shows

Four findings hold up on the documents.

First, NHTSA’s two senior AV-relevant posts were both filled in 2025 by people who came directly out of the autonomous vehicle industry. The Chief Counsel came from Motional’s legal leadership. The Administrator came from Apple’s autonomous vehicle program and an AVIA board seat. Between January and September 2025, one or the other of them ran the agency.

Second, two officials took official action affecting their prior industry while personal financial ties to that industry were still being unwound. Simshauser signed NHTSA’s first deregulatory AV actions roughly two months after his Motional severance payments ended, while still holding Motional restricted stock. Michael ran a $100 million autonomous vehicle funding challenge in the same window he sold an xAI position for a reported eight-figure gain and continued liquidating Uber stock.

Third, the timing is compressed. Bradbury was confirmed in March 2025, Michael in May, McMaster and Morrison in September, and Barrs in October. Simshauser arrived in January. Within nine months, DOT’s second-ranking official, the administrators of FHWA, NHTSA, and FMCSA, NHTSA’s Chief Counsel, and the Pentagon’s Chief Technology Officer were all newly seated, and AVIA issued public statements welcoming several of them by name.

Fourth, the pattern is not uniform. Barrs shows no AV industry money. Duffy divested before taking office. Bradbury’s tie is ideological rather than financial. Morrison’s AVIA seat ended over a year before his nomination and no post-confirmation trading was found. Reporting the whole set matters more than reporting the part that fits.

Every disclosure quoted here exists because federal law required it and the official filed it. The system produced these documents. What it has not produced is a public answer on whether any particular action crossed a line, and in several cases the documents that would answer that question are not publicly posted.

Limitations

The following could not be resolved through public records. Each is stated here rather than left out.

•  Derek Barrs’ CVSA Annual Conference line item. The compliance certification confirms a financial interest or payment tied to the September 24, 2025 conference required resolution before he took office. What it was is not stated in any public document located. Resolving it requires the full signed ethics agreement from OGE or DOT, or a records request to CVSA.

•  Jonathan Morrison’s signed ethics agreement. Not located after repeated searching. What recusal commitments he made regarding Apple or AVIA is unknown.

•  Emil Michael’s signed ethics agreement, and confirmation that his Uber position reached zero. Individual sale transactions are on the record. Whether they closed the position out is not confirmed. Whether Senator Warren’s March 2025 letter received a response committing to specific recusals is also unconfirmed.

•  Peter Simshauser’s ethics agreement or recusal terms covering Motional, if any exist. Chief Counsel is not a Senate-confirmed post, so it falls outside the public OGE posting process that covers the others in this brief. Any internal DOT ethics agreement would require a Freedom of Information Act (FOIA) request.

•  Which specific NHTSA filings, exemption requests, or dockets Simshauser personally signed on Motional’s behalf between 2020 and 2024. His agency biography describes the work in general terms. The filing-level record was not accessible through the sources used here.

•  Whether any FHWA action taken during McMaster’s tenure touched Grab Holdings, One Stop Systems, or Robinhood. Nothing was found. That is a negative finding across the sources searched, not a certification that nothing exists.

Closing the first five requires a Freedom of Information Act request or a paid legal research database. Neither was used in preparing this brief.

Research contributions

Jonathon identified the HNTB Corporation connection running through multiple DOT appointees and flagged the recusal architecture as the place to look. Shon assembled the initial background research on Derek Barrs and Sean McMaster, including the financial disclosure and autonomous vehicle policy threads that opened this line of inquiry. Their work located the ground this brief is built on.

Sources

U.S. Office of Government Ethics. Certification of Ethics Agreement Compliance, Derek Barrs, Administrator, Federal Motor Carrier Safety Administration. Signed December 19, 2025. extapps2.oge.gov

U.S. Office of Government Ethics. Certification of Ethics Agreement Compliance, Sean McMaster, Administrator, Federal Highway Administration. Signed December 12, 2025. extapps2.oge.gov

U.S. Office of Government Ethics. Periodic Transaction Report (OGE Form 278-T), Sean McMaster. Filed December 11, 2025, certified January 22, 2026. extapps2.oge.gov

U.S. Office of Government Ethics. Ethics agreement letter, Sean McMaster to Judith S. Kaleta, Designated Agency Ethics Official, U.S. Department of Transportation. April 4, 2025.

U.S. Office of Government Ethics. Certificate of Divestiture, Sean McMaster, OGE-2025-232.

ProPublica. Financial disclosure records for Derek Barrs, Sean McMaster, Jonathan Morrison, Peter Simshauser, Steven Gill Bradbury, Emil George Michael, and Sean Duffy, drawn from OGE Form 278e filings. projects.propublica.org/trump-team-financial-disclosures

National Highway Traffic Safety Administration. Leadership biographies, Jonathan Morrison and Peter Simshauser. nhtsa.gov

Federal Highway Administration. Administrator biography, Sean McMaster. highways.dot.gov

U.S. Senate Committee on Commerce, Science, and Transportation. Nomination hearing record and questions for the record, Jonathan Morrison, July 16, 2025. commerce.senate.gov

U.S. Senate Committee on Environment and Public Works. Written statement of Sean McMaster, nominee to be Administrator, Federal Highway Administration, May 14, 2025. epw.senate.gov

Federal Register. ADS-Equipped Vehicle Safety, Transparency, and Evaluation Program; Withdrawal. 91 FR 38619, June 26, 2026, citing open letters from NHTSA Chief Counsel Peter Simshauser dated April 24, 2025 and June 13, 2025.

Crowell & Moring LLP. NHTSA Announces First Actions Under Trump Administration’s New Framework for Removing Regulatory Barriers for Automated Vehicles. April 2025. crowell.com

Defense Innovation Unit. DIU and DAWG Launch Autonomous Vehicle Orchestrator Prize Challenge. diu.mil

DefenseScoop. Senate confirms former Uber executive as Pentagon’s chief technology officer, May 14, 2025; Pentagon CTO Emil Michael becomes acting director of DIU, August 26, 2025. defensescoop.com

The Guardian. US defense official overseeing AI reaped millions selling xAI stock after Pentagon entered agreement with company. April 9, 2026. theguardian.com

NOTUS. The Transportation Department’s Federal Highway Administrator Bought Stock in a Transportation Company. Dave Levinthal, March 18, 2026. notus.org

Office of U.S. Senator Elizabeth Warren. Letter to Emil Michael on ethics commitments, March 2, 2025. warren.senate.gov

Grab Holdings Limited. Grab to make strategic investment in remote driving technology company, Vay. Press release, November 10, 2025. grab.com

One Stop Systems, Inc. Company description. onestopsystems.com

The Heritage Foundation. Mandate for Leadership: The Conservative Promise, 2025 Presidential Transition Project, Chapter 19, Department of Transportation, author’s note. static.heritage.org

Transportation For America. Steven G. Bradbury, transit and Vision Zero opponent, named Deputy DOT Secretary nominee. February 5, 2025. t4america.org

U.S. Department of Transportation. Biography, Deputy Secretary Steven G. Bradbury. transportation.gov

Autonomous Vehicle Industry Association. Press releases on the nominations and confirmations of Steven Bradbury, Derek Barrs, and Jonathan Morrison. theavindustry.org

Congress.gov. Nomination records PN25-33 (Morrison), PN26-31 (McMaster), and PN55-4 (Barrs), 119th Congress.

AASHTO Journal. Senate Confirms Sean McMaster as FHWA Administrator, September 19, 2025. aashtojournal.transportation.org

Freight Culture Standard. Follow the Autonomous Money Trail, version 3, August 2026.