Circling back - we eventually managed to escalate to Exchange Online support. 
Since it wasn't our "tenant" that had the problem, it took a while.

Standard answers of "this is a rate change problem", asking if the IP was new. 
After showing them 30 days of traffic statistics, they reset the throttle but 
could not provide any reason why it got listed.

Graeme

From: Graeme Slogrove <[email protected]>
Sent: Tuesday, 4 May 2021 4:09 PM
To: [email protected]
Subject: [mailop] Sudden deferred deliveries to Office365

Hi,

At exactly midnight UTC, one of our servers started receiving the error

451 4.7.500 Server busy. Please try again later from [20.40.161.177]. (S77719)

The error codes seem to indicate a problem with IP throttling due to changes in 
traffic patterns, but our logs show less than 2% variance in traffic to 
Office365 from that IP address

Any ideas who to contact?

Regards,
Graeme Slogrove
Product Engineering

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