Tom Clancy's Splinter Cell HD

Whereas most games this’d be easy to achieve, it’ll only pop in your second playthrough when not going for the Passive Aggression trophy. You can get headshots with your pistol, but I’d use the sniper scope on your assault rifle by pressing and then to zoom in. On your normal playthrough you’ll want to take out many enemies with headshots. If not, grind the kills on any of the late levels where you are allowed to kill enemies. Kalinatek is a great mission for this, or Abattoir.