The NFL
passed a rule change that made this harder in 2017. Teams that do that can now be penalized with 15 yards and, more importantly, a clock reset.
It sounds like the determining factor is "multiple fouls on the same play". Here's my question: What if the Bills try to accomplish the same goal by sending out 12, or hell, 16 men on defense? It's not necessarily as guaranteed to stop the offense as intentionally holding all the WRs, but could still be pretty effective. Or would that count as "multiple fouls"?
I guess the question is, if you were a little more subtle about the cheating, could you get away with it? Clearly the NFL doesn't want teams to be able to manipulate the clock in those situations, but it sounds like the rule might still have some loopholes.