Letter to Racing CEOs regarding min bet intro

Dear Sam,

You will have seen that Racing Victoria have followed Racing NSW and announced the introduction of a minimum bet law from October 1.

It can be seen as the turning point for the industry and punters; that a fair, equitable and socially responsible market is what the industry wants and deserves.

Now would be the perfect time for you as CEO to liaise with your board and begin the process of introducing a minimum bet law on racing in your state. It will have a profound longterm impact on your turnover, especially as punters who have been finding it hard to get their bets on gravitate to NSW and Victoria where they know their hard work will be rewarded.

By introducing a minimum bet law you will only be upholding on course bookmaker betting obligations which your state has had for all of time.

Do you plan to introduce a minimum bet law?

I, and all punters in Australia look forward to your response.

Many thanks,

Richard Irvine

Yearly Open Letter to Bernard Saundry

Hi Bernard,

Because the ethical argument was not strong enough for you to bring in a minimum-bet limit for corporate bookmakers last year, I will set them aside and give you the regulatory and marketplace conditions that support Racing Victoria implementing a minimum bet limit when you evaluate your Race Fields Legislation mid-way through this year.

State Govt. support

Last May you said “We agree with the notion that legitimate punters should be able to bet to win a minimum amount on Victorian races, however, there remain legal impediments and operational challenges for us to achieve this exclusively via a minimum bet condition within our Race Fields Policy.”

So I wrote to Racing Minister Pakula and presented him with your words. Minister Pakula responded with “RV is responsible for setting appropriate conditions for WSP’s operating on Victorian thoroughbred racing. If RV were to make similar changes as NSW to its Race Fields Policy, I would consider any request to underpin such a regime with legislation”.

Minister Pakula finished with “I expect RV to continue to monitor the impact of the changes in New South Wales and make any necessary changes to its Race Fields Policy to ensure there is a competitive balance between punters and bookmakers”.

If you genuinely do believe punters should be able to have a chance to win when punting on Victorian racing, then the minister has set proper framework for you to pursue it. It’s obvious he will back you up with the full force of the Govt. if you implement a minimum-bet law. Since you placed min-bet in the too hard basket last year we have seen nothing from you in terms of working with the State Govt. towards a resolution for punters. If you try and fail with State Govt. support we can accept that – but you doing nothing we can’t. Legal impediments and procedures are no longer an excuse to not introducing a min-bet law.

Wider Industry Support

All major corporate bookmakers in Australia; Sportsbet, TabCorp, Ubet, Ladbrokes, UniBet, Bet365, Topsport and Crownbet, along with all minor corporates have respected and adhered to RNSW’s introduction of a minimum bet law some 18 months ago. The only major corporate not to is the unconscionable William Hill – and that is partly due to Waterhouse arrogance, and partly due to the current taxation system.

Your three major corporate bookmaker partners; CrownBet, Sportsbet and TabCorp, already bet all legitimate punters to win at least $1,000 on all Victorian racing.

Your joint venture partner TabCorp COO Craig Nugent, commented on RSN Radio when asked about winning punters “We want all customers. We want to give sophisticated gamblers the very best of content, the very best of information. There is a problem currently in the sophisticated market and we think there needs to be a solution”.

Both the Australian Bookmakers Association and the Victorian Bookmakers Association fully support you introducing a minimum bet law.

I contacted Racing Australia and asked them their thoughts on min-bet laws. They responded with  “We believe a minimum bet law to be a credible solution for bookmakers and punters on the issue of corporate bookmaker obligations and account restrictions.”


The only opposition has come from the 100% foreign interests of the Australian Wagering Council (AWC). The best reason against introducing a minimum-bet law they can come up with is that winning punters take the best odds which disadvantages losing punters who receive worse odds. A deeply embarrassing notion. And deeply insulting to the intellect of all Australian punters.

This notion is so obviously against Racing Victoria ideals. It would be akin to you telling Damien Oliver to ride with an extra 3kg in races to bring him back to the field.

Of course, anyone who understands fixed-odds market dynamics realise that when a winning punter backs a horse, that horse does firm, but that pushes the price of other horses out creating better value for the losing punters that the AWC is so worried about. This dynamic is paramount to driving turnover.

Further, the conditions of RNSW min-bet laws only allow winning punters access to markets from 9am on race day. Fixed odds markets have usually been up for 24 hours prior to that with all corporates – plenty of time for unrestricted punters to have unfettered access to all odds. RNSW min-bet conditions are very favourable to bookmakers. We would accept the same set of conditions from you.

You give bookmakers a licence to lay every runner and take a margin for themselves. The AWC believe that modern bookmakers should find losing gamblers and take their money. You have a responsibility to the community to not allow them to change the narrative of what modern bookmakers are licensed to do.


I support your current tax structure. It is the most expensive fixed-odds tax punters and bookmakers have ever faced – but it is justified in the face of the massive migration from tote to fixed odds. Racing’s funding must be secure during this migration.

William Hill claim that they can’t bet winning punters because of the impost of your current tax structure. But William Hill are welcome to, and should, pass on the 1.5% – 3% turnover tax you placed on them onto the punter via their fixed-odds markets. We can handle that. If it means we win a little less, or lose a little more each year, so be it. Racing’s funding must always come first.

Your turnover tax doesn’t really suit corporates betting best tote. But best tote doesn’t suit racing’s funding and it also is irrelevant in the min-bet argument as it doesn’t include best tote betting. I think William Hill are failing to separate the two.

William Hill’s problem is not turnover tax, rather that they paid way too much to gain access to the Australian market.

William Hill’s 2015 results were very interesting. They “implemented client management and trading changes to address unprofitable turnover following race field fee increases.” And were hammered with 20% drop in turnover and 41% drop in net profit. A terrible result for William Hill and a bad result for Racing Victoria. Sportsbet, who have embraced a fair market place had polar opposite results; revenue up 46%, profit up 78%. Unequivocal evidence that you need an unrestricted marketplace.

I do feel that charging bookies turnover or gross-profit tax on a per meeting basis is very unfair and does nothing to encourage turnover and needs to be addressed. The mechanics of it are simply too hard for bookmakers to manage.

Your Best Customers

Winning punters are your best customers. Whether it’s Race 1 at 10am on a heat affected day at Echuca, or Race 10 on a bitterly cold autumn night at Cranbourne, we’re there turning over money for you – trying our best to back a winner. Yet, it feels we get no support from you.

If you introduce minimum bet laws, the short term financial implications for the industry will be negligible – but long term it will have a massive impact. Because this generation and the next generation of winning punters (your best customers) won’t be extinct and the legacy of the punter bookmaker contest that is such an important part of Victorian racing’s history will be intact.

The chorus of disenchanted punters has doubled in the last year and will continue to multiply until you act.


Richard Irvine


Mr. O’Farrell,

When Treasurer Scott Morrison announced the review which you are chairing he said “I have deliberately left the terms of reference broad to ensure former Premier O’Farrell can look at everything he needs to, with no preconceived notions.” Therefore I have perused your review’s terms of reference but also formed my submission around what I believe to be the most important issues – from a punter’s perspective – for the Federal Government to consider.

  1. Problem Gambling; Corporate bookmakers overall have strong problem gambling infrastructures in place. I really don’t feel they need to do any more than they have already. However their level of advertising during live sport must change. They should be banned from having any part of telecasts. All other forms of advertising are acceptable. My generation and yours all grew up with no gambling around the sports we love – now, the next generation are coerced into thinking that the only way to enjoy live sport is to bet on it as well. This is most alarming when you consider the mostly rapacious conduct of the Corporate Bookmakers. Which leads me on…
  2. Minimum Bet Limits; It makes my blood boil when I see the blanket advertising Corporate Bookmakers throw at major sport in Australia knowing that the majority of them believe their bookmaking licence to be an entitlement, where the punter is merely fodder for their bottom line. Any punter that is not considered “economically viable” to a bookmaker has their account closed or severely restricted. Bookmakers offer people the opportunity to win money – that’s their product. They must be forced by the Federal Government to be true to this. Punter outrage over the last couple of years has led to some change from a minority of Corporate Bookmakers but there is still a long way to go. The bookmaking industry in Australia has been hijacked by foreign raiders who are intent on expanding the highly unethical business practices they have been allowed to get away with – mostly in U.K. and Europe – by ignorant, complicit regulators. These practices have had serious negative social impacts. The Federal Government must stand up to them. They are welcome here – but it must be to Australia’s advantage. Your review must either recommend introducing minimum bet limits for all Australian Corporate Bookmakers or explain to the Australian public why gambling should be allowed in society when no one can actually win at it?
  3. Illegal Offshore Wagering; the biggest threat is money being leaked to Asian betting exchanges. Punters are turning to these because they can’t get their bets on here because of account closures and restrictions but also because of the outdated, non-competitive structure of tote betting in Australia. Your review should begin talks between TabCorp., Tatts Bet and racing regulators about drastically overhauling tote-takeout rates. Tote-takeout rates of 18-20% are simply not viable long term in the digital age when compared with sportsbetting which has take-out rates of 3-5%. Many punters in Australia who have been barred by Corporate Bookmakers can bet on Asian betting exchanges and receive between 10-24% commission back on their bets. All punters want to support the Australian industry but when we have been treated so poorly for so long, betting with these Asian exchanges is most compelling.


Richard Irvine

Another offshore attack. Just let us bet.

From today’s AustralianRacing, police combine to end illegal betting agencies

It really is hard to know where to start with this one.

We know Patrick Smith isn’t the sharpest tool in the shed, but does he really believe that any bookmaker not licensed by an Australian state or territory represents “an unprecedented menace to all sport”?

The article is obviously prompted by Racing Victoria’s decision to make it “an offence for any licensed and registered person to bet on Victorian racing with betting agencies not approved by Racing Victoria”.

Good luck with that one. Most trainers and jockeys are smart enough not bet in their own name – why would they open a Citibet account in their own name?

But onto sport. We have this quote from the AFL general counsel, Andrew Dillon:


Interestingly, Dillon appears to be batting for the bookies in pushing for the in-play ban to be removed (it all but has been of course, with William Hill and Bet365 allowing it) as “the best way to counter the use of offshore illegal betting”.

We’ve got news for you Dillon. A good way to stop punters going offshore is to get bookies here to take a bet. You can start with your official wagering partner Crownbet who frequently deny $25 bets to winning customers.


Wonder why they go offshore when winning punters aren’t discriminated against at the likes of Pinnacle Sports with $10,000+ limits. Not to mention the revenue you are missing out on when your wagering partner only wants to accept bets from losing punters.


If sporting bodies like the AFL wanted to do something for “integrity” they would be pushing for a fair minimum bet rule in sport. It would surely be easier to enforce than in racing where multiple punters bet at the same time.

Back to today’s article. How could Smith add more credibility to the piece? Go the to Victoria Police for a quote. That’s right the same police force that is so knowledgeable about betting that they charged a score-dispensing courtsider with “conduct that would corrupt a betting outcome”.


“Because they operate outside of the law, they are able to appear more competitive”.. I assume he means the law (as he sees it) in Victoria and not the law where the bookmaker is registered?

Enough with all the misinformation. Just let winning punters get a fair bet on. Revenue to sporting bodies will increase and integrity concerns from money going offshore will be dramatically reduced.

Here’s a Classic(bet)!

The NSW Government licensed Classicbet really do hate winners. Here’s what they are asking for if they suspect that you might be somehow inclined to back more winners than losers:


After consideration we have decided to re-open your ClassicBet betting
account subject to the satisfactory completion and return of important
probity requirements.

In accordance with this, your account has been temporarily suspended
pending the receipt of these documents required by the ClassicBet
Compliance team.

Please complete the attached terms of trade with a Statutory Declaration
as to the bona fides of your betting account.

The completed Statutory Declaration must include the following
information and documents all of which must be verified by an authorised

a. Your full name, address, date of birth, and occupation;

b. ClassicBet pin or account ID;

c. Details and supporting documentation as to whether you operate your
betting account for yourself only, or on behalf of someone else;

d. Details of how you are funding your betting account;

e. Certified copies of the evidence of the source of funds deposited to
your ClassicBet betting account;

f. Certified copies of your last three tax assessments;

g. Certified copies of documents evidencing your current income e.g.
your last 3 employee payslips;

h. Printout of the IP address(es) for the computers used to operate your
betting account;


i. Details of the mobile phone numbers used to operate your account.

Where a certified copy of a document is required to be attached to the
Statutory Declaration, you will need

to have those documents certified by a Justice of the Peace, Solicitor
or Commissioner for Declarations.

Upon receiving the above information your account will be unsuspended
and available for betting.

Kind regards,

ClassicBet Compliance team


Mixed success. That’s how you could describe our campaign to get bookies to take a racing bet from winning punters. While some have reported a positive experience, it’s all too evident that many Australian bookmakers continue to thumb their nose at Racing NSW’s Minimum Bet rule. This is particularly the case with so-called “indicative pricing” where by winning punters are offered a lower price than that served up on a platter to losing punters. Ka-ching!

With the 2015 kick-off of the biggest game in the land – the AFL – it’s time to turn a little attention to sport.

Readers will no doubt be familiar with all the “betting scandals” that have enveloped the game of Aussie Rules over the summer. The latest involved Collingwood’s Jack Crisp placing bets on an AFL market totaling, wait for it – $129. At the same time, the AFL announced it had sacked a scoring official for the year after permitting 62 bets totaling $362 be placed using his account. Yes, the average bet was $6. Sacked!

Rule breaches they were, but announced from the rooftops in the name of INTEGRITY. How heroic.


Here’s what the AFL can do about integrity – force their wagering partners to take a bet from winning punters.

The AFL have revenue and information sharing agreements with most if not all Australian-licensed bookmakers. The AFL take a share of revenue generated from betting on the game and bookmakers sift through their records to match names and report any anomalies to the AFL Integrity Unit.

We also know that winning clients are severely restricted to amounts that are hardly even worth the trouble of logging in at just about each and every Australian-licensed bookie.

The same punters are exposed to tweets like this from Pinnacle Sports.com (licensed in Curacao (a Dutch island in the southern Caribbean sea) and Malta).


Here is what a winning punter can get on at the line with Sportsbet on Monday’s Hawthorn v Geelong match.



And here is what PinnacleSports.com will bet the same winning punter.





$217 versus $13,777.

The AFL kiss goodbye to the revenue and have no idea who is betting. That is where you lose INTEGRITY – not from $6 bets.

Force your partner bookmakers to bet punters a reasonable amount and they don’t need to head offshore.

Another scenario. Say I’m a dopey insider at an AFL club after a quick buck. I’ve got news that the three best players are out for the weekend. It’s Thursday afternoon and I’m about to beat the massive line move by placing a few bets at Pinnacle. He could most probably get three bets on – up to $40,000 – before a significant line move.

You think Pinnacle Sports will be divulging the name of the punter who sparked a plunge to the AFL? Players and officials, you know where to bet.

Open letter to Bernard Saundry, CEO of Racing Victoria

Hi Bernard,

I was heartened to hear you recently on RSN Radio say that Racing Victoria will consider Minimum Bet Laws for corporate bookmakers in May when you renew your race fields legislation.

It’s so important that RVL introduce and legislate Minimum Bet Limits and ban account closures.

It’s incongruous that ingenuity and a pursuit of excellence is nurtured and sought as a priority in every aspect of racing except punting.  The highly sophisticated industry that RVL is pushing towards must consider and protect punters into the future.

Fixed odds wagering is booming and is heading towards – in-terms of revenue for the industry – becoming an equal funding contributor as tote betting. Tabcorp just released half yearly results where fixed odds revenues were up 33%. Fixed odds revenues are up because that’s how punters want to bet these days – in particular the next generation of punters that RVL has been vocal about attracting. I’m part of that next generation; we’re smart and we have an abundance of information and computers available to us that previous generations didn’t. And that’s given so many more punters the opportunity to win on the punt – which is a great thing. But there’s no point to this “digital revolution” and initiatives like your own racing.com, if punters can’t at least potentially monetise this wealth of info.

I heard you on radio this morning talk in particular about RVL trying to attract 18-25 year olds as a priority. You went on to affectionately label them as “the next generation of race goers and my children” and how important it is that they learn about racing and engage with it. If RVL don’t act against the current corporate bookmaker climate, “your children” will be engaging with a gambling market that is a one-sided massacre akin to poker machines. Strong but realistic language.

The entire industry, from the Australian Racing Board to media commentators, right through to the tens of thousands of industry participants are tired of corporate bookmakers rapacious conduct, because Australian racing is based on integrity and fair go for all. 

On-course betting rings have always been regulated and fair, which is why we have the strongest marketplace in the world. RVL should act for no other reason than to impose the same regulations that they have placed on on-course bookies for all of time. You would no doubt have had meetings with the Australian Bookmakers Association, who have waged a long, patient and considered campaign to level the playing field for the hundreds of on-course bookies they represent, who face the most headwinds of all wagering operators.

The marketplace has improved slightly in the last year. And some corporates have listened to the industry and are now running equitable, fair and profitable businesses. And there has been a minute minority of corporates who have always run fair businesses. But there is still a number of large foreign corporates who believe their bookmaker’s license is an entitlement, and they shouldn’t be saddled with the competitive forces that every other business in Australia faces. A bookmakers license is the privilege of framing a market with the percentage in your favour, and going about laying every runner to make your margin. This seems to have been forgotten.

I acknowledge that the fractured state of national racing administration has made this issue a complicated one. But you have the resources to to act and I guarantee it will be to racing’s betterment. You will face push-back from disgruntled corporates who may argue that the new tax regimes have made it too hard for them to service “low-margin clients”. But that’s simply because they misread and over invested in the Australian marketplace. That’s not RVL’s problem, and it’s not the punter’s problem.

This issue will never go away. If you don’t act the industry will continue to be deprecated as people like me speak out against it. I don’t wish to be an antagonist, I just love racing and want a fair go.

There’s two types of punters in Australia; those who win and those who aspire to win. If RVL don’t act for all punters in May you will be telling winning punters to invest elsewhere, and aspiring winning punters that they are welcome so long as they lose. What happens when the aspiring winning punters realise that they’re just fodder?

You run the strongest racing jurisdiction in the world. All punters love racing in Victoria and want to support and engage with it – but Racing Victoria need to support us.


Richard Irvine