ACACIA NATIONAL VARIABLE ANNUITY SEPARATE ACCOUNT II
N-4, EX-99.9, 2001-01-16
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                                    EXHIBIT 9

                            Legal Opinion and Consent


<PAGE>


January 16, 2001


Acacia National Life Insurance Company
7315 Wisconsin Avenue
Bethesda, Maryland  20814

Gentlemen:

With  reference  to the  Registration  Statement  on Form  N-4,  filed by Acacia
National Life Insurance  Company and Acacia National  Variable  Annuity Separate
Account II with the Securities and Exchange Commission covering flexible premium
annuity  policies,  I have examined such documents and such laws as I considered
necessary  and  appropriate,  and on the  basis  of such  examination,  it is my
opinion that:

1.                Acacia  National Life Insurance  Company is duly organized and
                  validly  existing  under  the  laws  of  the  Commonwealth  of
                  Virginia  and  has  been  duly  authorized  by  the  Insurance
                  Department of the  Commonwealth  of Virginia to issue variable
                  annuity policies.

         2.       Acacia National Variable Annuity Separate Account II is a duly
                  authorized and existing separate account established  pursuant
                  to the provisions of Virginia, ss.38.2-3113.

2.                The flexible premium variable annuity policies, when issued as
                  contemplated  by said Form N-4  Registration  Statement,  will
                  constitute  legal,  validly issued and binding  obligations of
                  Acacia National Life Insurance Company.

I  hereby  consent  to  the  filing  of  this  opinion  as an  exhibit  to  said
Registration Statement on Form N-4.


Sincerely,


/s/Robert-John H. Sands

Robert-John H. Sands
Senior Vice President, Corporate Secretary and General Counsel




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