Freedom Holding Corp. — Director's Dealing 2008

Jul 3, 2008

SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: BMB MUNAI INC (KAZ)
CIK: 0000924805
Period of Report: 2008-02-08

Reporting Person: JSC Compass Asset Management (10% Owner)
Reporting Person: Compass Asset Management Ltd. (10% Owner)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock ($0.001 par value)	1321280	Indirect
Common Stock ($0.001 par value)	226716	Indirect
Common Stock ($0.001 par value)	3796215	Indirect

Footnotes

F1: Pursuant to two investment advisory agreements, Compass Asset Management Ltd. ("CAM"), a wholly-owned subsidiary of JSC
Compass Asset Management ("JSC"), has been appointed investment manager for two private funds, Compass Kazakhstan Ltd.
("Compass Kazakhstan") and Kazakh Compass Fund Ltd. (the "Kazakh Compass"). In addition, pursuant to such investment
advisory agreements, JSC agrees to act as the investment adviser to provide CAM with research and services to assist CAM in
executing the investment objectives of Compass Kazakhstan and Kazakh Compass subject to the terms and conditions of the
respective investment) management agreements to which Compass Kazakhstan and Kazakh Compass are a party. Compass Kazakhstan
and Kazakh Compass are wholly owned funds of CAM and act solely as investment vehicles for CAM.

F2: Pursuant to a shareholders' agreement, CAM and Spencer House Capital Management LLP ("Spencer House") formed a joint venture
in which each entity owns 50% of Spencer House Compass Capital Ltd. ("Spencer Compass"). Pursuant to a management
agreement, Spencer Compass acts as the investment manager with respect to the shares of common stock directly owned by TAU
Capital (Public Investments) Limited.