POULTON & YORDAN

ATTORNEYS AT LAW

 

 

RICHARD T. LUDLOW

 

November 11, 2009

 

 

Chris White

Branch Chief

United States Securities and Exchange Commission

Division of Corporate Finance

Washington, D.C. 20549

 

Dear Mr. White:

 

At the request of the management of BMB Munai, Inc., (the “Company” or “BMB Munai”) we are responding to comments raised by the staff at the Securities and Exchange Commission in your letter dated November 10, 2009. Following are the Company’s responses to your comments.

 

Form 10-K, Amendment No. 1, Filed October 23, 2009

 

Financial Statements

 

 

On November 12, 2009, the Company filed with the Commission a Second Amendment to its Annual Report of Form 10-K/A (the “Second Amendment”). Included on page F-1 of the Second Amendment is a revised report from the Company’s independent registered public accounting firm that references the restatements to the Company’s financial statements and that includes an updated report date with regard to the restatements.

 

 

 

Note 13 – Income Taxes, page F-30

 

 

The Company has included the word “restated” underneath the dates in the applicable columns of all restated charts in Note 13 Income Taxesof the Notes to the Consolidated Financial Statements. See pages
F-30 - F-32.

 

Thank you for your assistance in this matter. If you have any questions or require additional information, please contact me directly.