One point needs to be emphasised in relation to the United Kingdom legislation. From the outset, when the 1987 Act came into force, it had and was intended to have an international effect, because under section 3 the Director of the Serious Fraud Office was empowered to provide information obtained by the Director to foreign prosecution authorities, and to foreign investigative authorities if they fell within the definition of "competent authority" in sub-section (6). The Director was and is not in a position to assess the national interest of the United Kingdom or the other factors referred to in Article 2 of the 1959 Convention.

The Director therefore presumably has to seek the guidance about such factors of relevant government departments if a request for information (or a request to make a written agreement for the supply or exchange of information) is received from the authorities of a foreign state. No doubt run of the mill requests coming from the USA, the Commonwealth or EU member states are covered by general rather than specific guidance, while requests from other foreign countries are the subject of specific guidance.

In the light of the United Kingdom legislation we turn to consider the position in Guernsey. The power given by section 17(6) of the 1987 Act was exercised in relation to Guernsey by the Criminal Justice Act 1987 (Guernsey) order 1989. This order came into force on 18th May 1989 and was expressed by Article 1 to cease to have effect two years from that date. It extended section 2 of the 1987 Act to Guernsey with suitable modifications, including "Attorney General, in lieu of "Director". The effect of this extension was to make possible mutual assistance between Guernsey, England and Wales and Northern Ireland in the investigation of suspected serious fraud.