Tropico 5 - Penultimate Edition

First of all build a spy academy ,place a tycoon as manager ,In the constitution set the Economy structure to free market .This did take a bit of time make sure you keep a eye on the spy academy as I lost my first tycoon manager .When the achievement popped I had full staff and had 14/16 active agents .was also playing sandbox with unlimited money. Hope this helps. As gerbasgamer as confirmed you need more than 13 agents for it to pop.