[Poulton & Yordan's Letterhead]

                                October 18, 2005


April Sifford
Branch Chief
United States Securities and Exchange Commission
Washington, D.C. 20549

         Re:    BMB Munai, Inc.
                File No.: 0-28638
                Staff Comment Letter dated October 4, 2005

Dear Ms. Sifford:

         At the request of the management of BMB Munai, Inc., (the "Company" or
"BMB Munai") I am responding to comments raised by the staff at the Securities
and Exchange Commission in your letter dated October 18, 2005. Following are the
responses to your comments.

1.       Your disclosure indicated you intend to file restated financial
statements concurrently. Please tell us how, and when, you will file them.

         The Company filed its amended annual report on Form 10-KSB for the year
ended March 31, 2004, and its amended quarterly reports on Form 10-QSB for the
quarters ended June 30, 2004, September 30, 2004 and December 31, 2004 with the
Commission via its Edgar system on October 5, 2005.

2.   Please tell us if your certifying officers have considered the effect of
the error on the adequacy of your disclosure controls and procedures as of the
end of the period covered by your Forms 10-KSB and 10-QSB for the periods ended
March 31, 2004 and December 31, 2004. Additionally, tell us what effect the
error had on your current evaluation of disclosure controls and procedures as of
your fiscal year ended March 31, 2005.

         As I discussed with Gary Newberry, in the amended Forms 10-KSB and
10-QSB, the Company addressed the fact that in light of its decision to restate
its financial statements, it had concluded that the disclosure controls and
procedures in place at the time the initial reports were filed were not
effective. The amended reports go on to explain that the Company has implemented
new policies requiring its internal accounting staff to receive ongoing training
on accounting for oil and gas properties in accordance with generally accepted
accounting principles in the United States to prevent recurrence of future
errors of this nature and to strengthen the Company's internal control process.

Ms. April Sifford
October 18, 2005
Page 2


         Also, as discussed with Mr. Newberry, the Company believes the new
disclosure and control policies it implemented in response to this matter were
effective at the time the Company filed its Annual Report on Form 10-KSB for the
year ended March 31, 2005, as evidenced by the fact that the Company's financial
statements included in that report correctly reflect the proper accounting
treatment for the obligation due to the Republic of Kazakhstan.

         Attached to this letter, please find a statement from the Company
acknowledging that:

         o        the Company is responsible for the adequacy and accuracy of
                  the disclosure in the filling;

         o        staff comments or changes to disclosure in response to staff
                  comments do not foreclose the Commission or any person under
                  the federal securities laws of the United States; and

         o        the Company may not assert staff comments as a defense in a
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States.

         Thank you for your assistance in this matter. If you have any questions
or require additional information, please contact me directly.

                                                      Very truly yours,

                                                      POULTON & YORDAN

                                                       /s/ Richard T. Ludlow

                                                      Richard T. Ludlow
                                                      Attorney at Law


                            [BMB Munai's Letterhead]


                                October 18, 2005


April Sifford
Branch Chief
United States Securities and Exchange Commission
Washington, D.C. 20549

         Re:    BMB Munai, Inc.
                File No.: 0-28638
                Staff Comment Letter dated October 4, 2005

Dear Ms. Sifford:

         In connection with the Company's responses to comments raised by the
staff at the Securities and Exchange Commission in your letter dated October 18,
2005, the Company acknowledges that:

         o        it is responsible for the adequacy and accuracy of the
                  disclosure in its filings;

         o        staff comments or changes to disclosure in response to staff
                  comments do not foreclose the Commission or any person under
                  the federal securities laws of the United States; and

         o        it may not assert staff comments as a defense in a proceeding
                  initiated by the Commission or any person under the federal
                  securities laws of the United States.

         If you have any questions or require additional information, please
contact me directly.

                                                            Sincerely,

                                                             /s/ Adam R. Cook

                                                            Adam R. Cook
                                                            Corporate Secretary