SecProbe.io

Mail Stop 4628
December 1 7, 2015

Timur Turlov
Chief Executive Officer
BMB Munai, Inc.
324 South 400 West
Suite 150
Salt Lake City, Utah 84101

Re: BMB Munai, Inc.
 Form 8-K
Filed November 23, 2015
File No. 001 -33034

Dear Mr. Turlov :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Completion of Acquisition or Disposition of Assets, page 3

1. We note that Mr. Turlov owns 80.1% of your out standing stock.  Include a brief
discussion of your status as a controlled company after the recent acquisition and pending
acquisitions.

Business, page 5

Overview, page 5

2. We note that currently, Freedom RU and Freedom KZ execute U.S. securities
trans actions through an intermediary affiliated with Mr. Turlov in Cyprus.  Please
disclose the name of the intermediary and Mr. Turlov’s affiliation.  Also, disclose the
name of the U.S. clearing broker -dealer responsible for executing and clearing the
custome rs’ orders.

Timur Turlov
BMB Munai, Inc.
December 1 7, 2015
Page 2

 3. We note your clearing arrangement with Lek Securities  Corporation .  Please clarify
whether, to date, you have executed securities transactions in the United States for the
account of others.

Regulation, page 11

4. Given that your business will require  you to register as a broker -dealer with the SEC and
become a member of FINRA, tell us when you plan to initiate those applications.

Exhibits, page 50

5. We note that you have entered into a clearing arrangement with Lek Securities
Corporation.   Please file the clearing agreement as an exhibit, or alternatively tell us why
you believe it is not required to be filed.  Refer to Item 601(b) of Regulation S -K.

FFIN Securities, Inc.

Table of Contents, page F -2

6. Disclosure in your filing states that  the acquisition agreement entered into with Timur
Turlov in November 2015 provides for the possible acquisition of the entities identified
as the “Freedom Companies” in your filing.  We note your statements that you have
agreed to acquire these entities f rom Mr. Turlov and that his interest in your common
stock would increase from approximately 80% to approximately 95% after giving effect
to these acquisitions.  Please tell us how you considered the guidance per Rule 8 -04 of
Regulation S -X with regard to p robable acquisitions.

Financial Statements for the Three and Six Months Ended September 30, 2015, page F -14

7. Please revise to present a statement of operations and a statement of cash flows for the
period from August 25, 2014 (inception) – September 30, 2 014.  Refer to instruction 1 to
Rule 8 -03 of Regulation S -X.

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 the information the Securities Exchange Act of
1934 a nd all applicable Exchange Act rules require.   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.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

Timur Turlov
BMB Munai, Inc.
December 1 7, 2015
Page 3

  staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or Ethan  Horowitz,
Branch Chief, at (202) 551 -3311 if you have questions regarding comments on the financial
statements and related matters.  Please contact Anuja A. Majmudar , Attorney -Advisor, a t (202)
551-3844  or me at (202) 551 -3745 with any other questions.

Sincerely,

        /s/H. Roger Schwall

H. Roger Schwall
Assistant Director
Official of Natural Resources