Less than 24 hours after President Javier Milei's national address promising to pursue rigorous administrative and criminal action against hydrocarbon exploitation in the Malvina Islands, the national government took its first operational step. Through the Ministry of Foreign Affairs, it formally initiated sanction proceedings against 45 individuals and legal entities for alleged violations of Article 2 of Law No. 26,659 ("Solanas Law"), which expressly prohibits the exploration, extraction, transport, and financing of hydrocarbons on the Argentine continental shelf without the express authorization of the Republic's authorities.

The administrative summary, which covers companies, investment funds, directors, technical consultants and contractors based in 11 international jurisdictions (United Kingdom, Israel, Canada, United States, Netherlands, Denmark, Sweden, Kazakhstan, South Africa, Jersey and British Virgin Islands), puts the spotlight on the corporate heart of Sea Lion .

The state payroll confirms point by point the publications and heritage investigations that Agenda Malvinas has been consistently revealing over the last few years.

A look at the 45 sanctioned entities: the key players investigated by this media outlet

The Foreign Ministry's list breaks down the value chain that supports the project's structure in the North Malvinas Basin and adjacent blocks:

LIST OF ENTITIES AND PERSONS UNDER INVESTIGATION

1.  NAVITAS GROUP (Operator 65% Sea Lion) :

• Companies: Navitas Petroleum Dev. & Prod. Ltd / Navitas Atlantic Ltd.

• Funds/Shareholders: Harel, Migdal, The Phoenix, Meitav. 

• Directors/Members: Gideon Tadmor Cohen, Boaz Tadmor, Amit Kornhauser, Yacob Katz, Jonathan Sternberg.

 2. ROCKHOPPER GROUP (35% shareholder):

 • Empresas: Rockhopper Exploration (Hydrocarbons) Ltd / (Oil) Ltd.

 • Fondos: Noked Capital, Exodus Management, Ion Fund, Aedos Advisers. 

 • Chief Executives: Samuel "Sam" Moody and William Rees Perry.  

3. JHI GROUP / ECO ATLANTIC (Block PL001):   

• Companies: JHI Associates Inc., JHI Malvinas Inc., Eco Atlantic.    

• Financistas: Canaccord Genuity, CIBC Asset, Avanza Bank, Westmount.

• Key shareholders: Moshe Peterburg, Askar Alshinbayev, Coronation.  

4. INFRASTRUCTURE, SERVICES AND AUDIT:

• Noble Corporation (Plataformas) + Accionistas (AP Moller, Vanguard, First Eagle, Dimensional).                                   

• Netherland, Sewell & Associates Inc. (NSAI) (Technical certification body).

• Fugro NV (Geotechnical and underwater surveying).

• Borders & Southern Malvina Islands Ltd. and its shareholders.

From operators to City banks and reserve consultancies  

The most salient evidentiary aspect of the process opened by the Foreign Ministry is that it abandons the abstract sanction on the corporate seals and points to the financial and technical mechanisms that this media outlet documented in detail:

Background and the challenge of real-world application

In the preamble to the measure, the Government emphasized that "the Malvina Islands, South Georgia and the South Sandwich Islands and the corresponding maritime and insular spaces are Argentine. By history and by law. There is no discussion," warning that those who seek to profit from the usurped resources will encounter "the full force of the law."

Both Rockhopper and Navitas already had prior declarations of clandestinity ( Energy Secretariat Resolutions 133/2012 and 240/2022 ). The new development lies in the fact that the Foreign Ministry's file seeks to extend the disqualifications to directors in their personal capacity, to institutional investment funds (such as Harel, Phoenix, or Vanguard), and to logistics and consulting companies .

The opening of the sanctioning process confirms the seriousness of the reported scenario: Sea Lion has ceased to be a hypothetical project and has become a fully operational transnational structure . Now, the challenge for the Argentine State will lie in transforming administrative notifications into effective precautionary measures and international embargoes, preventing the placement banks, the Texas certification companies, and the platform contractors from continuing to operate with absolute impunity on the sovereign continental shelf.