NAF Procurement

Authorizes DoD nonappropriated fund instrumentalities (NAFIs) to enter into certain contracts and agreements with other federal agencies and instrumentalities in accordance with the authorities in sections 2484(h)(2)(A) and 2492 of Title 10, United States Code (U.S.C.) (Reference (c))

• DoWI 4105.67 Nonappropriated Fund Procurement Policy and Procedures Updated July 17, 2026

Providing a list of identified applicable and non-applicable laws and policies for NAF Procurements. This is an ever-changing environment, so there will be periodic updates.

• NAF Procurement Applicable Laws and Policies Updated Dec. 2, 2025

• Legal Approved Clause Listing

Department of Labor

1. Sweat & Toil: Child Labor, Forced Labor, and Human Trafficking around the World Application
2. Comply Chain: Business Tools for Labor Compliance in Global Supply Chains

U.S. Customs and Border Protection

1. An Informed Compliance Publication (Washington, D.C.: Sept 2017). What Every Member of the Trade Community Should Know: Reasonable Care.
2. Trade Programs and Administration on Forced Labor and Withhold Release orders and Findings. Withhold release order is issued when information is reasonably but not conclusively indicates that merchandise produced with forced labor is being, or likely to be imported into the United States.

Department of State, Treasury Commerce, Homeland Security, Labor; and the Office of Trade Representative

1. Xinjiang Supply Chain Business Advisory: Risks and Considerations for Businesses and Individuals with Exposure to Entities Engaged in Forced Labor and other Human Rights Abuses linked to Xinjiang, China (July 13, 2021)
2. Responsible Sourcing Tool. Combating Trafficking in Persons.

Office of Management and Budget

Anti-Trafficking Risk Management Best Practices & Mitigation Considerations, (Washington, D.C.: Oct, 2019)

Public Law and Reports

• GAO-02-256, Defense Management: Industry Practices Can Help Military Exchanges Better Assure That Their Goods Are Not Made by Child or Forced Labor, January 31, 2002
• GAO-22-105056, Forced Labor: Actions Needed to Better Prevent the Availability of At-Risk Goods in DoD’s Commissaries and Exchanges, February 3, 2022
• Public Law 112-239, 1704a(1) Monitoring and investigation of trafficking in persons
• Public Law 112-239, 1705(2) Notification to inspectors general and cooperation with Government.
• United States Code, Title 22, Section 7104 b(a)(1) Prevention of trafficking -Text contains those laws in effect on September 5, 2023
• United States Office of Management and Budget, Memorandum on Anti-Trafficking Risk Management Risk Management & Mitigations; October 21, 2019