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    Amana Mutual Funds Trust

    1300 N. State Street

    Bellingham, Washington 98225

    September 15, 2025

    VIA EDGAR FILING and EMAIL

    Division of Investment Management

    Securities and Exchange Commission

    100 F Street, NE

    Washington, DC 20549

    Attn:  Ms. Eileen Smiley

          Re:

            Amana Mutual Funds Trust (File Nos. 002-96924 & 811-04276) (the “Registrant”)

            Response to Staff Comments – Rule 485(a) Post-Effective Amendment

    Dear Ms. Smiley:

    This letter responds to the comments provided by the staff (the “Staff”) of the U.S. Securities and
      Exchange Commission (“SEC”) on August 29, 2025, concerning Post-Effective Amendment No. 64 to the Registrant’s Registration Statement on Form N-1A (the “Post-Effective Amendment”). The Post-Effective Amendment was filed with the SEC on July 15, 2025,
      pursuant to the Securities Act of 1933, as amended, and Rule 485(a) of Regulation C thereunder, and pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”), and the regulations thereunder. You requested that written responses to
      the comments be provided via EDGAR correspondence. Accordingly, the Staff’s comments and the Registrant’s responses are set forth below. Unless otherwise noted, defined terms have the same meanings as in the Post-Effective Amendment.

    General

              1.

              Where a comment is made with regard to disclosure in one location, it is applicable to all similar disclosure appearing elsewhere
                in the registration statement.

    Response: The Registrant acknowledges the above.

              2.

              We note that portions of the filing are incomplete or to be updated by amendment. To the extent that the filing is incomplete,
                please confirm that the next post-effective amendment will be complete.

    Response: The Registrant confirms that the next
      post-effective amendment will complete or update as required the information in the registrant statement.

              3.

              The Registrant and its management are responsible for the accuracy and adequacy of the disclosures, notwithstanding any review,
                comments, action, or absence of action by the Staff.

    Response:  The Registrant acknowledges the above.

      Ms. Eileen Smiley

      Office of Disclosure and Review

      Securities and Exchange Commission

      September 15, 2025

      Page 2

    Prospectus

              4.

              The Amana Income Fund’s prospectus states that the Fund will “invest at least 80% of its total net assets in
                income-producing securities, primarily dividend-paying common stocks (the “80% Policy”).” Please explain supplementally to the Staff and expand the disclosure to address what other income producing securities the Fund can invest in
                directly, since you state that the primary investments will be common stock.

    Response: The Registrant confirms that the primary investments
      of the Amana Income Fund will continue to be common stock. As of May 31, 2025, per the Amana Income Fund’s Schedule of Investments, 90.4% of investments were in common stock. The remaining assets were cash and dividends receivable from stock. The
      Fund is not changing its investment objective, principal investment strategy, or its 80% Policy.

    The Registrant filed the Post-Effective Amendment to add disclosure to  permit the Amana Income Fund,
      Amana Growth Fund and Amana Developing World Fund, each of which invests primarily in stocks, to invest uninvested cash in Islamic income-producing investments (murabaha and wakala). Because Islamic principles preclude the use of interest-paying
      investments, the Funds’ cash positions cannot be invested in traditional money market funds or investments such as U.S. government or agency securities, and currently the Funds’ cash positions do not earn interest income. The murabaha and wakala
      investments would be used for the Funds’ cash positions and not as a part of the principal investment strategy. To provide exposure to murabaha and wakala investments in a manner that is consistent with the “qualifying income” requirement applicable
      to a “regulated investment company” under the Internal Revenue Code, each such Fund will gain exposure to these investments through its wholly-owned and controlled subsidiary. The subsidiaries will invest in murabaha and wakala investments and may
      invest in other short-term Islamic income-producing investments.

              5.

              Because these Funds had the ability to invest in wholly-owned subsidiaries before, please explain to the Staff whether the Funds
                expect to invest a greater percentage in the wholly-owned subsidiary to achieve each Fund’s objective.

    Response: Please refer to the response to Comment 4 above. The
      Amana Participation Fund is the only series of the Registrant that currently can invest in a wholly-owned subsidiary which invests in Islamic income-producing investments. The Registrant filed the Post-Effective Amendment to add disclosure that
      permits the other three Funds (Amana Income, Amana Growth, and Amana Developing World) to earn income on cash positions by investing in Islamic income-producing investments through a wholly-owned subsidiary. Each of the three equity Funds expect to
      invest in its wholly-owned subsidiary to a limited extent for purposes of gaining exposure to Islamic income-producing investments for cash positions, and in any case no more than 20% of the Fund’s total assets.

              6.

              The Item 9 disclosure on page 25 of the prospectus states the maximum percentage that  can be invested in the
                wholly-owned subsidiary. Please include this information in the Item 4 disclosure for each Fund as well.

    Response: The Registrant confirms that this
      disclosure will be included in the Item 4 disclosure for each Fund.

              7.

              The third paragraph under the heading “Principal Investment Strategies” on page 3 of the prospectus includes the
                following statement: “Because Islamic principles preclude the use of interest-paying instruments, the Fund’s cash reserves do not earn interest income.” The following paragraph provides: “The Fund will seek to gain exposure to murabaha and
                wakala investments for its cash balances by investing …” Please explain what is meant by “cash balances” or revise the terminology to clarify the disclosure.

    Response: The term “cash reserves” or “cash balances” refers to uninvested cash that is part
      of the Fund’s portfolio. A Fund may hold a larger cash position in its portfolio, for example, during periods in which there is a lack of suitable investment opportunities or during adverse market, economic, political, or other conditions. The
      Registrant will revise the disclosure to ensure the terminology used is more consistent.

      Ms. Eileen Smiley

      Office of Disclosure and Review

      Securities and Exchange Commission

      September 15, 2025

      Page 3

              8.

              Consider consolidating the more detailed disclosures regarding the operation of the wholly-owned subsidiaries, including the disclosures
                requested in Comment 18 below, in the Item 9 disclosure, and including more streamlined disclosures in Item 4.

    Response: The Registrant will consolidate the more
      detailed disclosures regarding the operation of the wholly-owned subsidiaries in the Item 9 disclosure in the prospectus and include more streamlined disclosure in Item 4.

              9.

              The principal investment strategy disclosure for each Fund says that the Fund may invest in murabaha. Please add the risks of investing
                in murabaha as a principal risk in the summary prospectus of each Fund.

    Response: The Registrant will add disclosure describing
      the risks of investing in murabaha as a principal risk in the summary prospectus of each Fund.

              10.

              Please apply Comments 4-8 above to the prospectus for each of Amana Growth Fund and Amana Developing World Fund.

    Response: The Registrant will apply
      Comments 4-8 to the prospectus for each of Amana Growth Fund and Amana Developing World Fund.

              11.

              With respect to Amana Developing World Fund, on page 13 of the prospectus in the “Principal Investment Strategies” section, please
                disclose how the Fund is defining “production assets” and clarify this point in the disclosure.

    Response: The Fund is defining “production assets” as property or
      equipment used by a company. The Registrant will clarify this point in the disclosure.

              12.

              With respect to Amana Participation Fund, please add in an appropriate place in the Fund’s Item 4 disclosure the
                Fund’s non-diversified status and its ability to concentrate in the two industries identified in Item 9.

    Response: The Registrant notes that the Amana Participation
      Fund’s Item 4 disclosure currently includes disclosure about the Fund’s non-diversified status and its ability to concentrate its investments within the financial services industry and the real estate sector, under the heading “Principal Risks of
      Investing.” The Registrant will revise the prospectus to include this disclosure in Item 4 under the “Principal Investment Strategies” heading as well.

              13.

              The “Principal Investment Strategies” section in Item 9 provides:
                  “The adviser, Saturna Capital Corporation, selects investments. To ensure that investments meet the requirements of the Islamic faith, the adviser engages Amanie Advisors Sdn Bhd, a leading consultant specializing in Islamic
                finance.”

    Please provide more information about the nature of the Funds’ relationship with Amanie with respect to
      determining whether investments meet the requirements of the Islamic faith. Please address supplementally whether or not Amanie should be considered an investment adviser of the Fund as defined in Section 2(a)(20) of the Investment Company Act of
      1940. If not an adviser, please explain supplementally whether Amanie should be treated as an expert for purposes of Section 7 under the Securities Act of 1933.

    Response: Saturna Capital Corporation (“Saturna Capital”) has
      engaged Amanie as a consultant on the requirements of Shariah and compliance with Shariah principles. Saturna Capital is solely responsible for selecting the securities or other property in which the Funds invest, and it determines Shariah compliance
      based on its own security selection and compliance processes and procedures. Amanie evaluates Saturna Capital’s compliance processes and procedures,  reviews reports of fund holdings from time to time, and provides information on whether the Funds
      are operating are in line with Shariah principles. Amanie does not provide any investment advice or recommendations to the Funds or Saturna Capital as to the course of action that the Funds should take with respect to any investments.

      Ms. Eileen Smiley

      Office of Disclosure and Review

      Securities and Exchange Commission

      September 15, 2025

      Page 4

    Saturna Capital is each Fund’s investment adviser, and it is the sole entity responsible for
      determining what securities or other property are purchased or sold by each Fund. Section 2(a)(20) of the 1940 Act defines “investment adviser” of an investment company to mean: (A) any person (other than a bona fide officer, director, trustee,
      member of an advisory board or employee of such company, as such) who pursuant to contract with such investment company regularly furnishes advice to such company with respect to the desirability of investing in, purchasing or selling securities or
      other property, or is empowered to determine what securities or other property shall be purchased or sold by such company; and (B) any other person who pursuant to contract with a person described in clause (A) above regularly performs substantially
      all of the duties undertaken by the person described in clause (A) above. The definition also provides that an investment adviser does not include a person who furnishes only statistical and other factual information, advice regarding economic
      factors and trends, or advice as to occasional transactions in specific securities, but without generally furnishing advice or making recommendations regarding the purchase or sale of securities. The Registrant believes that Amanie would not fall
      within such definition. First, with respect to clause (A) above, Amanie does not have a contract with the Funds, does not furnish advice to the Funds with respect to the desirability of investing in any particular security or other property, and it
      has no power or ability, by contract or otherwise, to determine what securities are purchased or sold by the Funds. Rather, Amanie consults on the requirements of Shariah and compliance with Shariah principles. Such compliance consultation is not
      investment advice. Second, Amanie does  not regularly perform substantially all of the duties undertaken by Saturna Capital, so it is also not within clause (B).

    Amanie should not be treated as an expert for purposes of Section 7 under the Securities Act of 1933.
      Section 7 of the Securities Act of 1933 provides that an expert is “any accountant, engineer, or appraiser, or any person whose profession gives authority to a statement made by him.” The Registrant respectfully submits that Amanie is not among the
      class of persons subject to Section 7 as “expert” unless the Registrant expressly identifies such providers as experts or the statements are purported to be made on the authority of such providers as “experts.”

              14.

              The Staff notes that “Subsidiary Investment Risk” appears to be more robust in the disclosure with respect to
                Amana Income Fund, Amana Growth Fund and Amana Developing World Fund than it is with respect to the Amana Participation Fund. Please make the risk disclosure consistent.

    Response: The Registrant will make the “Subsidiary Investment
      Risk” disclosures consistent.

              15.

              Page 25 of the prospectus says: Each Fund may, after taking into account any assets that do not satisfy the 80% Policy, invest up to 20%
                of its total net assets in in a wholly-owned and controlled subsidiary (“Subsidiary”), to gain exposure to short-term Islamic income-producing investments (murabaha and wakala) for its cash balances.” However, the first paragraph on the
                preceding page says that the Participation Fund may invest up to 25% of its total net assets in its Subsidiary. Please reconcile the disclosure on the preceding page.

    Response: The Amana Income Fund, Amana Growth Fund, and Amana Developing
      World Fund may each invest up to 20% of its total net assets in its Subsidiary. The Amana Participation Fund has a different limit – it may invest up to 25% of its total net assets in its Subsidiary. The Registrant will review and revise the
      disclosure to provide clarity on this difference.

    Wholly Owned Subsidiary

              16.

              With respect to each Fund, please supplementally confirm in correspondence to the Staff that:

              a)

              The Subsidiary’s management fee (including any performance fee), if any, will be included in “Management Fees,” and the
                Subsidiary’s expenses will be included in “Other Expenses” in the Fund’s fee table.