Nuclear energy trade, given its dual-use nature in both peaceful and non-peaceful applications, has long been subject to multilayered regulation at national and international levels. Internationally, instruments such as the Treaty on the Non-Proliferation of Nuclear Weapons (NPT), UN Security Council resolutions, sanctions, and mechanisms like the Nuclear Suppliers Group (NSG) constitute the main frameworks of control. The central question addressed in this study is what elements a functional legal structure for regulating nuclear energy trade should contain. The findings suggest that drafting specific regulations tailored to the unique characteristics of nuclear energy, together with diverse and effective enforcement mechanisms, is essential for the efficiency of such a legal framework. At the national level, the United States presents a clear and detailed model by adopting independent legislation and a variety of enforcement measures to effectively regulate nuclear trade. By contrast, Iran has yet to adopt comprehensive and codified regulations within an independent framework, creating a significant gap in its legislative system. Through a comparative analysis of the two legal systems, this study highlights the shortcomings of Iran’s regulatory approach and offers practical recommendations for strengthening its legal and institutional framework.