SecProbe.io

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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
      June 6, 2006

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 April 11, 2006
		File No. 000-28638

  		Form 10-QSB/A for the period ended December 31, 2004
		Filed April 11, 2006
		File No. 000-28638

Dear Mr. Cherdabayev:

      We have reviewed you response letter dated May 17, 2006, and
the
amended filings and have the following comments.  Once we complete
the
petroleum engineering review of your filing, we will issue any
related
comments in a separate letter.  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.

Selling Security Holders, page 14

1. Identify as underwriters all selling security holders who are
affiliates of registered broker-dealers, unless you can confirm to
us
that such selling security holders purchased the securities in the
ordinary course of business and have no agreements or
understandings,
directly or indirectly, with any party to distribute the
securities.

2. We note that in amendment 1 to your registration statement you
added 992,000 shares of common stock issued to a number of named
parties.  We note that these sales occurred in December 2005 after
the
filing of the initial resale registration statement and that you
then
added these securities to your pending registration statement.  It
is
therefore unclear to us how you can conclude that the purchasers
of
the securities took with investment intent or without a view to
distribute.  Rule 152 of the Securities Act provides a safe harbor
to
separate the issuance and resale transactions for 4(2) offerings.
However, the rule appears to be unavailable to you, since Rule 152
requires that the registration statement be filed subsequent to
the
4(2) offering.  Please provide us with a detailed analysis as to
why
you believe that you are able to add the securities from the
December
2005 private placement to the pending registration statement.

Form 10-KSB/A-2 for the year ended March 31, 2004

Controls and Procedures, page 3

3. Please revise to provide the information required by Item 8A of
Form 10-KSB.  Note that the item requires you to include
information
required by Items 307 and 308 of Regulation S-B.  We also refer
you to
Rule 12b-15 of the Exchange Act, which requires the inclusion of
the
complete text of each form item as amended.  Similarly, revise the
Controls and Procedures section of your Form 10-QSB for the period
ended December 31, 2004.

* * * * *

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 or, in her absence, the undersigned, at (202)
551-
3740.

      	Sincerely,

      					H. Roger Schwall
      Assistant Director

cc: 	R. Poulton
      C. Moncada-Terry
Gateway Enterprises, Inc.
BMB Munai, Inc.
June 6, 2006
Page 4

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