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<SEC-DOCUMENT>0000000000-06-052994.txt : 20061113
<SEC-HEADER>0000000000-06-052994.hdr.sgml : 20061110
<ACCEPTANCE-DATETIME>20061031161640
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-06-052994
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20061031

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			BMB MUNAI INC
		CENTRAL INDEX KEY:			0000924805
		STANDARD INDUSTRIAL CLASSIFICATION:	CRUDE PETROLEUM & NATURAL GAS [1311]
		IRS NUMBER:				300233726
		FISCAL YEAR END:			0331

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		C/O POULTON & YORDAN
		STREET 2:		324 SOUTH 400 WEST SUITE 250
		CITY:			SALT LAKE CITY
		STATE:			UT
		ZIP:			84101
		BUSINESS PHONE:		801-355-2227

	MAIL ADDRESS:	
		STREET 1:		C/O POULTON & YORDAN
		STREET 2:		324 SOUTH 400 WEST SUITE 250
		CITY:			SALT LAKE CITY
		STATE:			UT
		ZIP:			84101

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	INTERUNION FINANCIAL CORP
		DATE OF NAME CHANGE:	19960719
PUBLIC REFERENCE ACCESSION NUMBER:		0001038838-05-000922
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      November 23, 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
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. Disclose how the securities being registered for resale were
acquired by the selling security holders.

2. Identify as underwriters all selling security holders who are
registered broker-dealers, unless you can confirm to us that such
selling security holders received their shares as compensation for
investment banking services.

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

Controls and Procedures, page 30
1. We note that, in addition to your disclosure that the
disclosure
controls and procedures were not effective as of the end of the
reporting period covered by the amended report, you include
disclosure
indicating that "your disclosure controls and procedures are now
effective."  Revise to expand the disclosure to explain how
management
has determined that disclosure controls and procedures are now
effective.  Make similar revisions to your Form 10-QSB/A for the
quarter 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.
November 23, 2005
Page 2


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