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Jennifer Kelly; Illicit Finance and Economic Threats Team

Week of Monday, November 8, 2021

A giant clam as part of a healthy coral reef [1]

Organized criminal groups are profiting from the illegal harvesting of giant clams, with the Philippines recently identified as a prime location for this criminal activity. Philippine authorities have conducted at least 14 seizures of illegally harvested giant clams since 2017, totaling an estimated black market value of 85 million USD.[2] While authorities could not identify any criminal entities responsible for the operations, they believe the criminals recruited locals to harvest the protected clams by deceptively claiming they had government permits.[3] Merchants often use giant clam shells as a substitute for elephant ivory, particularly in China, where authorities implemented a ban on the import of elephant tusks in 2018.[4] It is almost certain that the continued illegal harvesting of giant clams in the region will have a destructive impact on the coral reefs, likely resulting in a decline in marine life. Such an impact on the fish populations would very likely lead to a loss of income for fishers and would likely place economic strain on the Philippine government to fund preservation and breeding programs in the region. Despite the increased awareness of illegal harvesting activities, criminal entities will likely continue to exploit reserves of giant clams in the Philippines unless law enforcement implements more significant security measures.

Illegal giant clam harvesting is a profitable business of organized criminal groups in Southeast Asia, specifically in the Philippines.[5] It is very likely that illicit clam harvesting activities occurred in the area long before Philippine authorities began to discover stockpiles of illegally harvested clams in 2017, due to the abundance of giant clams in the region and the lucrative profits from the sector. Stockpiling the heavy clams almost certainly indicates the operation was well organized, involved a large network of people, and was conducted over an extended period. Law enforcement was likely not aware of the operations partly due to limited resources dedicated to the monitoring and investigation of clam harvesting. It is likely authorities were alerted to the operations and received information about the activities from local individuals who realized the criminal groups deceived them.

Giant clams are a protected species, with international trade limited due to their vulnerably low populations.[6] Philippine law enforcement did not actively police the illegal giant clam trade until the first seizures in 2017.[7] Lack of previous law enforcement involvement is likely related to the illegally harvested giant clams not evoking substantial loss of tax revenue to the State. The Philippines almost certainly incur a cost from illegal harvesting through the implementation of more significant security measures and law enforcement training to prohibit future poaching. It is very unlikely that locals involved in illegal giant clam harvesting would have willingly participated if they had known it was a crime. Locals almost certainly do not wish to eradicate the protected giant clam from local waters as the species plays an important role in the vitality of reef systems that fishers rely on for food and commerce.

Philippine authorities could not officially identify the destination countries or the supply chain of the illegally harvested clams discovered in the Philippines.[8] However, the criminals responsible likely planned to transport these clams to the Chinese market. Between 2016 and July 2021, Chinese authorities reported at least 46 seizures of illegally harvested giant clam shells, with the South China Sea believed to be the source of the majority of the shells.[9] Due to the geographic proximity of the two countries, poachers likely transport clams from the Philippines to China by sea. The 2018 Chinese ban on importing ivory almost certainly increased the demand for giant clam shells, which very likely attracted the attention of both domestic and international criminals as an opportunity to generate illicit profits. The inability of Philippine authorities to detect illegal harvesting implies it is very unlikely they would have the maritime or border resources to detect and disrupt these sea routes successfully. Illegally harvesting vulnerable clam species will almost certainly lead to a decline in populations and an increase in their value, likely attracting more criminals to the industry and to the Philippines.

Illegal giant clam harvesting has devastating impacts on the environment, as satellite imagery from 2016 revealed Chinese poachers destroyed more than 40 square miles of coral reefs in the South China Sea due to illegal harvesting activities.[10] It is almost certain that the illegal harvesting of the recently discovered giant clams has caused further destruction to these coral reefs in the South China Sea, and created new areas of concern in the other seas surrounding the Philippines. The destruction of coral reefs leaves them incapable of sustaining marine life, almost certainly resulting in significant financial losses to local fishers.[11] Fishers already experiencing financial losses from the regulations imposed during the COVID 19 pandemic will unlikely be able to sustain further economic stress. Fishers will likely sail to other locations not affected by illegal clam harvesting in an attempt to circumvent these economic challenges and increase the volume of their hauls. An abundance of fishing vessels migrating to the same areas will likely lead to overfishing and the endangerment of various marine species. Funding breeding programs to revive dwindling numbers of fish will likely place substantial economic strain on the Philippine government.

The Philippines experienced a period of poaching and overharvesting of giant clams in the 1970s, leading to the species almost becoming locally extinct.[12] Scientists and marine biologists responded by rearing clams at marine labs before relocating them back to different coral reefs and successfully re-establishing the species over 30 years.[13] If the illegal harvesting of giant clams continues at the current rate in the Philippines, it is almost certain poachers and criminal groups will eradicate the species in the region and render decades of population recovery efforts obsolete. An extinction of giant clams in the Philippines would almost certainly place greater pressure on other regions where the species is plentiful, such as Australia’s Great Barrier Reef.[14] It is almost certain that the transfer of illegal giant clam harvesting operations to Australia would have a devastating impact on the Great Barrier Reef, likely resulting in erosion of the Australian coastline, placing homes and businesses in danger. In the Philippines, it is very likely that attempts to reintroduce the giant clams would be costly, and there is a roughly even chance Philippine institutions will be reluctant to fund it if there has already been a failed attempt. Without more stringent monitoring by law enforcement, it is very unlikely that criminal groups will stop attempting to profit from illegally harvesting giant clams.

The Counterterrorism Group (CTG) will continue to monitor and assess developments in the illegal harvesting of giant clam shells in the Philippines and neighboring regions through its Illicit Finance and Economic Threats (IFET) and PACOM Teams. The IFET Team will monitor illicit financial flows stemming from the illegal harvesting of giant clam shells and collaborate with the PACOM Team to identify criminal networks responsible for the operations. Both Teams will collectively identify other possible threats in the Philippines and the region. The CTG’s Worldwide Analysis of Threats, Crime, and Hazards (W.A.T.C.H.) officers will remain vigilant to threats in the PACOM region by monitoring global events 24/7 and producing relevant reports.

The Counterterrorism Group (CTG) is a subdivision of the global consulting firm Paladin 7. CTG has a developed business acumen that proactively identifies and counteracts the threat of terrorism through intelligence and investigative products. Business development resources can now be accessed via the Counter Threat Center (CTC), emerging Fall 2021. The CTG produces W.A.T.C.H resources using daily threat intelligence, also designed to complement CTG specialty reports which utilize analytical and scenario-based planning. Innovation must accommodate political, financial, and cyber threats to maintain a level of business continuity, regardless of unplanned incidents that may take critical systems offline. To find out more about our products and services visit us at

________________________________________________________________________ The Counterterrorism Group (CTG)

[2] Giant Clam Shells, Ivory, and Organized Crime: Analysis of a potential new nexus, Wildlife Justice Commission, 2021,

[3] Ibid

[4] As seizures of poached giant clams rise, links to ivory trade surface, Mongabay, October 2021,

[5] Giant Clam Shells, Ivory, and Organized Crime: Analysis of a potential new nexus, Wildlife Justice Commission, 2021,

[6] A Philippine community that once ate giant clams now works to protect them, Mongabay, July 2019,

[7] Giant Clam Shells, Ivory, and Organized Crime: Analysis of a potential new nexus, Wildlife Justice Commission, 2021,

[8] Ibid

[9] Ibid

[10] Giant Clam Poaching Wipes Out Reefs in South China Sea, National Geographic, July 2016,

[11] Scientists are trying to save coral reefs. Here's what's working, National Geographic, June 2020,

[12] Raising Giants, Hakai Magazine, August 2019,

[13] Ibid

[14] Giant Clam, Great Barrier Reef Foundation, n.d.,



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