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Grey listing is a wonderful spam filtering technique, which uses a
behavior trick: spammers never resend a message when they get a
temporary error, whereas real MTA do. The idea is to refuse any mail
on first attempt, and accept it after some time has elapsed.
  
milter-greylist is a stand-alone milter written in C that implement
grey listing. It's still quite experimental, but it has been seen
working on a real life MX.