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                                                                   EXHIBIT 10.23

                        Administrative Services Agreement

                                     between

                  ALLSTATE LIFE INSURANCE COMPANY OF NEW YORK,

                                       and

                                   ALFS, INC.

This Administrative Services Agreement ("Agreement") is made effective as of
JANUARY 1, 2002, between ALFS, INC. ("ALFS") and ALLSTATE LIFE INSURANCE COMPANY
OF NEW YORK ("ALICNY").

                                   WITNESSETH:

WHEREAS, ALICNY, a domestic New York life insurer, proposes to issue to the
public certain variable insurance contracts (the "Contracts"); and

WHEREAS, ALFS, which is registered as a broker-dealer with the Securities and
Exchange Commission, proposes to act as principal underwriter on an agency (best
efforts) basis in the marketing and distribution of Contracts to be offered for
sale by ALICNY; and

WHEREAS, ALICNY desires to obtain the services of ALFS as an underwriter and
distributor of certain Contracts issued by ALICNY; and

WHEREAS, in that capacity ALFS will be required to perform certain services and
to incur certain expenses in connection with the Contracts; and

WHEREAS, ALFS desires that ALICNY assume financial and administrative
responsibility for these expenses and services.

NOW, THEREFORE, it is agreed as follows:

1.   OBLIGATIONS OF ALFS

     ALICNY appoints ALFS as the principal underwriter of and its exclusive
     representative for the distribution of the Contracts and ALFS agrees to use
     its best efforts to arrange for the sale of the Contracts by other
     registered broker-dealers and licensed insurance agencies. With the consent
     of ALICNY, ALFS may execute selling agreements with duly qualified
     broker-dealers and licensed insurance agents of ALICNY to offer and sell
     the Contracts. The selling agreements shall contain such terms, including
     but not limited to provisions for commissions, as ALICNY shall deem
     appropriate. There will be no secondary distribution

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     of the Contracts. It is further understood and agreed that ALFS, which is
     not licensed as an insurance agent, shall not be required to act as such
     pursuant to this Agreement.

2.   OBLIGATIONS OF ALICNY

     A.   COMMISSIONS

          ALICNY agrees to assume on behalf of ALFS responsibility for the
          processing and payment of sales commissions payable to authorized
          persons in connection with the marketing of the Contracts. Such
          commissions will be processed and paid as directed by, and on behalf
          of, ALFS in accordance with the applicable selling agreement then in
          effect with such persons. ALICNY will not exercise any discretion over
          the amount of the commissions, and such commissions paid by ALICNY
          will be a purely clerical and ministerial function and will be
          properly reflected on the books and records maintained by ALICNY on
          behalf of ALFS.

     B.   CONFIRMATIONS

          ALICNY will send on behalf of ALFS confirmations of transactions in
          connection with the marketing of the Contracts to contract owners in
          accordance with the provision of Rule 10b-10 under the Securities
          Exchange Act of 1934 (the "Exchange Act"), and such confirmations will
          indicate that they were sent on behalf of ALFS.

     C.   RECORDKEEPING

          ALICNY will maintain and preserve books and records on behalf of and
          as agent for ALFS that ALFS is required to maintain in connection with
          the OFFER and the Contracts, and all books and records relating to
          confirmation of transactions in compliance with Rules 17a-3 and 17a-4
          under the Exchange Act. ALICNY agrees that all such books and records
          will remain the property of ALFS and will be subject to inspection by
          the Securities Exchange Commission and the National Association of
          Securities Dealers, Inc. ("NASD") in accordance with Sections 17 and
          15A of the Exchange Act.

     D.   MARKETING

          All expenses in connection with the marketing and advertising of the
          Contracts shall be the responsibility of ALICNY and not ALFS. ALICNY
          shall furnish ALFS with currently effective prospectuses with respect
          to the Contracts in such quantities as ALFS shall reasonably require
          for distribution to broker-dealers. ALFS will not directly market the
          Contracts to the general public.

3.   EXPENSES AND COSTS

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     A.   ALICNY agrees, as the sole compensation payable by it with respect to
          services performed by ALFS pursuant to Section 2, to assume on behalf
          of ALFS responsibility for the costs described above and any other
          overhead and operating expense that may be directly incurred by ALFS
          in connection with the marketing and distribution of the Contracts.
          ALICNY further agrees to assume on behalf of ALFS responsibility for
          costs incurred by ALPS in connection with state and regulatory
          licensing fees and certain audit, legal and professional fees, which
          services may change FROM time to time. Any costs and expenses incurred
          directly by ALFS shall be billed to ALICNY. A statement, together with
          supporting information, shall be furnished to ALICNY within 30 days
          following the end of each calendar quarter, and ALICNY shall pay any
          undisputed amount within 15 days of receipt of such statement. Any
          allocation of costs and expenses shall be made consistent with New
          York Insurance Department Regulation No. 33

     B.   Cost(s) shall mean ALFS' actual costs and expenses reasonably
          attributable to all services covered by this Agreement.

4.   BOOKS AND RECORDS

     A.   Records supporting inter-company costs and expense charges paid by
          ALICNY pursuant to Section 3 shall be maintained by ALICNY and shall
          be available to ALFS upon request. All original documents and records
          relating to the operations of ALFS shall be the property of ALFS.

     B.   Each party shall own, have custody of and keep its own general
          corporate records. Upon request, each party shall receive from the
          other party any of its records that are currently in the other party's
          possession.

     C.   The parties agree to keep all records required by federal and state
          securities laws and state insurance laws, to maintain the books,
          accounts and records so as to clearly and accurately disclose the
          precise nature and details of the transactions and to assist one
          another in the timely preparation of records. ALICNY shall furnish to
          ALFS any reports and information which ALFS may request for the
          purpose of satisfying its reporting and recordkeeping requirements
          under the federal and state securities laws or under the applicable
          rules of the NASD.

     D.   The parties further agree that all records shall be subject to
          production and inspection at the request of any governmental or
          regulatory agency with jurisdiction over ALFS or ALICNY. Any records
          maintained by ALFS on behalf of ALICNY hereunder shall be maintained
          in accordance with New York Insurance Department Regulation No. 152.

5.   GENERAL PROVISIONS

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     A.   Either party may terminate this Agreement by giving the other party
          written notice of the date upon which termination shall take place.

     B.   Each party shall be deemed an independent contractor and its personnel
          shall not be deemed to be the employees of any of the other parties
          solely by reason of this Agreement. ALICNY employees performing duties
          hereunder at all times during the term of this Agreement shall be in
          the employment, under the respective supervision and responsibility of
          ALICNY.

     C.   This agreement shall no be assignable by either party except with the
          written consent of the other. Any assignment of this agreement shall
          be subject to non-disapproval by the New York Insurance Department
          pursuant to Section 1505 of the New York Insurance Law.

     D.   Any dispute by the parties with respect to this Agreement shall be
          subject to arbitration in accordance with the Commercial Arbitration
          Rules of the American Arbitration Association. Unless otherwise agreed
          by the parties, the arbitration shall take place in the state of New
          York.

     E.   This agreement replaces all prior agreements among the parties
          relating to the services and expenses covered herein.

IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed
and ratified by their duly authorized officers as of the day and year above
written.


ALLSTATE LIFE INSURANCE COMPANY            ALFS, INC.
OF NEW YORK


BY: /s/ John Roger Hunter                  BY: /s/ Lisa A. Burnell
   ---------------------------                ---------------------------
TITLE:      V.P.                           TITLE:   AVP & Compliance Officer
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