Heya,
I just came out with something like this:
deny !condition = ISAUTH
!senders = :
message = No "Received:" header found in message.
log_message = No "Received:" header found in message. RCPT: $recipients
condition = ${if ={$received_count}{1}}
As far as I know, MTAs are obligated to send "Received:" headers. This
seems to be catching spam not caught otherwise.
Just in case you were interested.