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                                POULTON & YORDAN
                                ATTORNEYS AT LAW


--------------------------------------------------------------------------------
RICHARD T. LUDLOW

                                 March 22, 2006



Carmen Moncada-Terry
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010

                  Re:   BMB Munai, Inc.
                        Preliminary Proxy Statement on Schedule 14A, as amended
                        Originally Filed February 28, 2006
                        File No.: 000-28638

Dear Ms. Terry:

         This letter will confirm to you that BMB Munai, Inc. (the "Company") is
aware that, under Note A to Schedule 14A, if the Company currently has present
plans, arrangements, proposals or obligations to issue any of the new shares of
common stock , which would be created by approval of the amendment to increase
the capital shares of the Company, the Company would be required to provide the
additional information called for by Items 11, 13 and 14 of Schedule 14A.

         As we have discussed with you and disclosed in the preliminary proxy
statement, despite the Company's intention to make acquisitions in the near
future, currently the Company has not reached any preliminary or definitive
acquisition terms on any specific acquisition or property.

         Further, this letter will confirm that the Company has sufficient
authorized shares of capital stock available for immediate issuance to
accomplish any potential acquisitions it is currently considering, without
resort to any new shares that would be created by shareholder approval of the
proposed amendment to the Articles of Incorporation of the Company, as described
in the Company's preliminary proxy statement.

         Since the Company is not relying upon the shareholder decision to
increase the authorized share of capital stock of the Company as a condition to


                      POULTON & YORDAN    TELEPHONE: 801-355-1341
         324 SOUTH 400 WEST, SUITE 250    FAX: 801-355-2990
            SALT LAKE CITY, UTAH 84101    POST@POULTON-YORDAN.COM
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Ms. Moncada-Terry
March 22, 2006
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making any acquisitions currently under consideration, no disclosure regarding
any acquisitions is required by Items 11, 13 and 14 of Schedule A is required.

         Thank you for your assistance in this matter.

                                                 Very truly yours,

                                                 POULTON & YORDAN


                                                  /s/ Richard T. Ludlow
                                                 ------------------------
                                                 Richard T. Ludlow
                                                 Attorney at Law
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