Okay, think I have found it
Have a look at /opt/zimbra/postfix/conf/master.cf.in on line 111. When amavisd has finished its checks it injects the email back into Postfix on port 10025. The line Code:
-o receive_override_options=no_header_body_checks,no_unknown_recipient_checks,no_address_mappings
overides the defauls and no header/body checks are performed. You would need to remove the no_header_body_checks part and restart ZCS so that they are indeed performed. The rationale is that your own server should be sending out SPAM email
I have not tested this so no warranty implied