SecProbe.io

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      November 30, 2005

Mr. Boris Cherdabayev
Gateway Enterprises, Inc.
BMB Munai, Inc.
3230 East Flamingo Road, Suite 156
Las Vegas, Nevada 89121

      Re:	BMB Munai, Inc.
		Registration Statement on Form SB-2
      Filed October 21, 2005
		File No. 333-129199

		Form 10-KSB/A for the year ended March 31, 2004
		Filed October 5, 2005
		File No. 000-28638

Dear Mr. Cherdabayev:

      We have reviewed your filing and have the following
engineering
comments.    Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.  After reviewing this
information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We
look forward to working with you in these respects.  We welcome
any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

SB-2 filed on October 21, 2005

Summary Historical Reserve and Operating Data, page 4

1. Please remove the dollar signs under the production information
for
each period shown here and on page 33.

Risk Factors, page 5

	A substantial or extended decline in oil and natural gas
prices....., page 6

2. Please include in this risk factor the fact that you currently
receive materially lower prices than world market prices for crude
oil
and your gas price is substantially lower than that received in
North
America.

3. Please include a risk factor that states under the terms of
your
current exploration contract  you only have the right to produce
until
the year 2007 and that 94% of your proved reserves are scheduled
to be
produced after 2007.  There is no guarantee whether the current
license will be extended or a new commercial exploration and
production contract will be granted.

Business and Properties, page 28

	Oil and Natural Gas Reserves, page 30

4. You state that Chapman Engineering used oil and natural gas
prices
in effect during March 31, 2005 which you disclosed was $15.17 for
the
year ended March 31, 2005.   However, the reserve report uses an
oil
price of approximately $21.00 per barrel which is 38% higher than
the
price you disclose in the filing.   Please explain this to us.

Production, page 31

5. You state that you produced no natural gas during the month of
August 2005, however, you disclose 41.7 BCF of proved gas
reserves.
Please explain this to us.

Recent Developments, page 34

6. You indicate that you have tested several wells such as the
Dolinnoe 2 and Emir 1 wells in June 2005. Please disclose the
results
of this testing and if you think it is representative of the
wells`
long term production trends.  Along bring this production up to
date
as possible.

Our Properties, page 36

7. You disclose that you own a 100% interest in a production
license
and the current royalty rate is 2%.  You further disclose that
when a
commercial license is negotiated royalty rates can range from 2%
to
6%.  This would appear to give you a 94 to 98% net interest.
However,
we are not aware of any production contracts that are so
beneficial to
the grantee of the license.  Disclose whether at any time the
government has an option to participate or increase their net
interest
in the subject reserves.  Provide us a copy of this contract or
revise
your document to make any corrections necessary in this
disclosure. We
may have further comments.

8. Please revise your filing to give the results of the well work
you
disclose such as the re-entering well in the Akaaz, Emir and
Dolinnoe
fields and the two new wells drilled in the Dolinnoe field.

9. Tell us if you are the operator of all of your oil and gas
properties.

Title to Properties, page 39

10. You state that you believe you have satisfactory title to all
our
properties.  As we understand you have an interest in a license to
use
subsurface mineral resources and a hydrocarbon exploration
contract.
However, this does not imply you have title to or ownership in any
reserves but only a contractual right to explore and produce.
Please
clarify your document as necessary.

Results of Operations, page 42

	Costs and Operating Expense, page 44

11. You state that you incurred $206,929 in "selling expenses"
during
the fiscal year ended March 31, 2005 but these costs were not
included
as operating costs.  Please explain to us what this is.

Revenue and Production, page 46

12. As you produced 41,456 barrels of oil for the three months
ended
June 30, 2005 and derived revenues of $662,637 in the same period
it
would appear that your average oil price was $15.98 per barrel and
not
$17.98 as you disclose.  Also for the three months ended June 30,
2004
it appears the average oil price should be $10.43 per barrel.
Please
revise your document or explain to us why it is not necessary.

Notes to the Consolidated Financial Statements, page F-7

	Long Term Liabilities, page F-16

13. Tell us who PGS Reservoir Consultants are and the services
they
provide to you.

Supplementary Financial Information on Oil and Natural Gas
Exploration
Development and Production Activities (unaudited), page F-23

14. Tell us why if you had 41.7 BCF of proved developed gas
reserves,
you had no gas production during FY 2005.   Unless you can show
evidence of long term gas contracts or a robust spot market we do
not
believe the gas reserves can be classified as proved.  Tell us the
source of the $0.50 per Mcf gas price used by the consultant in
his
reserve report.

15. It appears from your oil production during FY 2005 it will
take
198 years to produce just your developed oil reserves and 33 years
to
produce the proved producing reserves assuming oil production does
not
change.  As all production will decline over time explain to us
how
this amount of developed reserves meets the requirements of
reasonable
certainty to be produced under Rule 4-10(a) of Regulation S-X.

16. There are several material differences between the
undiscounted
and discounted before and after tax cash flow numbers in the
reserve
report compared to the SMOG numbers in the filing.  Please
explain.

Reserve Report as of April 1, 2005

17. We note for the proved developed consolidation of the 5 wells
on
the ADE Block you have assumed production will increase from 874.4
barrels of oil per day to 1,887.5 barrels of oil per day.  Tell us
what the current production from these wells are and the basis of
assuming production from the existing wells will more than double
in
2006.

18. You have estimated each of these proved developed wells to
have
proved reserves of over 2.7 million barrels per well.  Tell us how
you
arrived at this estimate and why it meets the requirements of
reasonable certainty under Rule 4-10(a) of Regulation S-X.

19. We note that the decline rate of the Aksaz 1, 4 and the two
proved
undeveloped wells are estimated to be 2.0% per year.  Tell us how
you
arrived at this estimated decline rate.  We also note a very
modest
rise in the GOR over time for these wells.  Tell us how you
estimated
this.

20. Tell us the reason you make capital investments of $2 million
in
2005 and $3,500 million in 2006 for the proved developed reserves
in
the ADE Block.

21. You cannot reduce the fixed costs after five years based only
on
an assumption that operations will "reach stability" by then.   If
costs are fixed, then it can not be assumed that they will be
materially lower at some point in the future.  We are not clear on
how
fixed costs could change so dramatically but if these costs
actually
are materially reduced at sometime in the future, then at that
time
you may use lower costs in the reserve estimates.  Until then
please
revise your estimate based on current fixed costs being held
constant
as required by Rule 4-10(a) of Regulation S-X.

22. It is not appropriate to not attribute some general
administration
costs to the field operations.  Please revise your estimate to
incorporate these into your reserve estimate.

23. Provide us with the oil gravity and the reasons 80 and 160
acres
and 30% are reasonably certain for the drainage area and the
recovery
factor for these wells.  We do not feel that only anecdotal
evidence
about recovery efficiency is sufficient for proved reserves.  Tell
us
the reservoir drive mechanism you assumed and the bubble point
pressure of each of the reservoirs.  Tell us the reason for
assuming
the gas-oil ratio will remain relatively stable over the
productive
life of the reservoir.

24. Tell us if you have core data and what that information is.
Tell
us the permeability values for the reservoirs in each field.

25. Tell us if you limited proved reserves to lowest and highest
known
oil by well penetration.

26. Tell us the total life of the proved reserves for each
reservoir.

27. We note the Dolinnoe #1 well has declined at an approximate
rate
of 40% per year in 2004 and 2005.  Therefore, it appears that your
forecasted rates and decline rate cannot be supported.  Please
revise
the reserves based on the actual performance to date.

28. For the Emir proved undeveloped wells it is not appropriate to
assume productive rates 3 times higher than the rates actually
seen in
the Emir #1 well.  Please revise your estimates accordingly.

29. It is not clear to us why 2 offset PUD Emir wells will have
more
than 5 times the reserves of the proved developed well.  If this
is
due only to the initial higher production rates assigned to these
wells, then the reserves should be reduced as the rates are
reduced
based on the comment above.  If there are other reasons for these
higher reserves please indicate them to us or alternatively reduce
the
reserves.

30. Tell us if you attribute proved reserves to the Lower Triassic
interval in any of the three fields on the ADE Block.  If so, tell
us
which ones.   Tell us if the Lower Triassic has been production
flow
tested in any of the fields.  If so, tell us the fields it was
tested
in and the results.

* * * * *
Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Act of 1933
and
that they have provided all information investors require for an
informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosures
they have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      If you have any questions, please contact Carmen Moncada-
Terry
at (202) 551-3687 for legal issues or if you have petroleum
engineering questions please call James Murphy (202) - 551-3703 or
in
their absence, the undersigned, at (202) 551-3740.

      					Sincerely,

      					H. Roger Schwall
      Assistant Director

cc: 	R. Poulton
      C. Moncada-Terry
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Gateway Enterprises, Inc.
BMB Munai, Inc.
November 30, 2005
Page 2

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