SecProbe.io

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                                 June 20, 2006

H. Roger Schwall
Assistant Director
Division of Corporate Finance
Mail Stop 7010
United States Securities and Exchange Commission
Washington, D.C. 20549

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

Dear Mr. Schwall:

         As Corporate Secretary of BMB Munai, Inc., (the "Company") pursuant to
Rule 461, I hereby request that the effective date of the BMB Munai, Inc. SB-2
registration statement be accelerated to Monday, June 26, 2006 at 9:00 a.m.

         This offering is not being underwritten and no broker dealers are
participating in the distribution. Therefore, compensation review by the NASD is
not required and has not occurred.

         The Company acknowledges that:

         1)       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;

         2)       Any 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

         3)       The Company specifically acknowledges that it 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.

         Thank you for your assistance in this matter. If you have any questions
or require additional information, please contact me directly, or you may
contact our corporate and securities counsel, Richard Ludlow.

                                                     Yours very truly,

                                                     BMB MUNAI, INC.

                                                      /s/ Adam R. Cook

                                                     Adam R. Cook
                                                     Corporate Secretary

   BMB Munai, Inc. * 324 South 400 West, Ste. 250, Salt Lake City, Utah 84101
                 * Tel: (801) 355-2227 * Fax: (801) 355-2990 *

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