THE ACACIA GROUP LOGO
                7315 Wisconsin Avenue . Bethesda, MD 20814 . (301) 280-1000
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July 30, 1999




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


Gentlemen:

With  reference  to the  Registration  Statement  on Form S-6  filed  by  Acacia
National  Life  Insurance  Company and Acacia  National Life  Insurance  Company
Separate Account I with the Securities & Exchange  Commission  covering flexible
premium life insurance 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 to issue  individual  flexible premium variable life policies by
     the Insurance Department of the Commonwealth of Virginia.

2.   Acacia  National  Life  Insurance  Company  Separate  Account  I is a  duly
     authorized  and  existing  separate  account  established  pursuant  to the
     provisions of the Code of Virginia, Section 38.2-3113.

3.   The survivorship  flexible premium variable  universal life policies,  when
     issued  as  contemplated  by said  Form S-6  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 the said Form
S-6  Registration  Statement and to the use of my name under the caption  "Legal
Matters" in the Prospectus contained in the Registration Statement.

Sincerely,


/s/Robert-John H. Sands

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


Acacia Mutual Holding  Corporation o Acacia Financial Group,  Ltd. o Acacia Life
Insurance  Company o Acacia National Life Insurance  Company o Acacia  Financial
Corporation o Calvert  Group,  Ltd. o Acacia  Federal  Savings Bank o Enterprise
Resources, LLC o Acacia Realty Corporation o The Advisors Group, Inc.
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NATIONAL HEADQUARTERS, Washington, DC