Sadly this is not the case.
I unlocked a "bully" achievement which was given for having 3 players booked in a single match. I know for a fact that I've had that happen before (as a general rule if a player gets booked I sub him and I know I've had it in the past where I have used all 3 subs on that). I also got another "achievement" for a player being sent off for spitting at the ref.
Not too sure if stuff like that should really be counted as "achievements" however.
I've also got my star striker on 108 league goals, yet the 100 goal achievement is still locked.