|Awarded for an average foul rate of less than 1 per match in your 10 most recent matches.|
This can be tricky as I think off-sides actually count as fouls, so the easiest way is to play 10 games in league mode, 5 minute matches (on easy) and just keep the ball and pass it amongst your defenders. The reason for this is that you could try play normally, but it increases your chances of fouling an opponent or being off-side. This is also the easiest way in which to get the Possession Play achievement.
Again, this is not possible to unlock in online matches.
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