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The word תַּחַת is often translated "under". In Ex 19:17 it means "at the base of" (the people do not stand literally under a mountain), and it sometimes has other meanings. The meaning here is almost certainly positional in some way due to the mem prefix and adjoined lamed (see section 7b here).

The simplest explanation is that מִתַּחַת refers to all bodies of water. Water is always lower than -- below -- the adjacent land. Some water actually comes from below ground too, like springs, and we learn from Genesis 7:11 that sea-water comes from the depths below. But the present passage isn't telling us that the only forbidden inspirations for aquatic idols come from below the earth we're standing on; it's a broader reference to oceans, lakes, rivers, etc.

In the Masoretic tradition the phrase וַאֲשֶׁר בַּמַּיִם | מִתַּחַת לָאָרֶץ: is one phrase, not two, but there is a slight pause after "in the waters" before "under the earth" (where the vertical bar is in what I just quoted). Think of this as a comma but not a semicolon nor a full stop. I'm not sure if this affects how we should interpret the text, but I thought I'd point it out. The trope (which implies punctuation) is not part of the original text but is a received tradition recorded centuries later.


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