Without applying other antispam rules? I don't think so. The only thing I can think of is to use a milter like mimedefang (
http://mimedefang.org) and test for the encoding of the body in the filter() section.
This site has an example using the subject instead of the body:
http://lists.roaringpenguin.com/pipermail/mimedefang/2009-April/034698.htmlThis is not for the faint-of-heart and you really need to know some perl, or be able to figure it out.