Tom Clancy's H.A.W.X.
51 Achievements
PS3
Not safe enough
Kill an enemy with a missile while being jammed in a multiplayer match.
9.0%
How to unlock the Not safe enough achievement in Tom Clancy's H.A.W.X. - Definitive Guide
Aspect Missiles are the best to use when you are jammed. This will be easier said than done though and the chances of getting this without a boosting partner are pretty low.