I had an issue with one of the mail servers on which one user’s account password was stolen and was sending spam. Spam was sent from Roundcube and there was a very large number of recipients in one email. Limit the number of recipients in Postfix was not an option. It had to be done on webmail. It is very simple with Roundcube. Just add variable bellow in your Roundcube configuration file – config.inc.php.
$config['max_recipients'] = 10;
This will allow only 10 recipients in one email message. Of course you can change the number according to your needs.