Well - on behalf of my customer (and I'm billing them for it) I opened a case through my O365 account about how O365 is assigning BCL 9 to an email from their domain, for seemingly everyone in O365.
After more than an hour on the phone, we left it with me sending MS some headers and a mailtrace.
They did point out some nice tools I thought I would share.
https://sender.office.com
This site allows you to request MS to remove an IP from MS's black lists.
https://testconnectivity.microsoft.com/
This site has a Message Analyzer tab now - at least I never noticed it before. it can analyze headers.