In order to get this trophy/achievement, you will need to use a Pay ‘n’ Spray whenever you have a wanted level. When you do something in the vicinity of the police, you will get a wanted level, which will cause them to come after you to either arrest you, or if you did a lot of bad things, kill you. One way to get rid of your wanted level is to use a Pay ‘n’ Spray, which are shown as spray cans on your map. These will remove all of your wanted level, no matter how high, but the stars will be flashing after using one.

If you commit a crime while they are flashing, then your full wanted level from before using the Pay ‘n’ Spray will be reinstated. After a minute or so with them flashing, the wanted level will go away. You don’t need to do the latter, but simply using the Pay ‘n’ Spray will unlock this. In fact, you should get this during some of the early missions, since they will require you to use the Pay ‘n’ Spray as an actual objective.