This is not a dumb question at all. As the rules don't specifically provide an answer on how SARs apply to a deceased customer, it can be confusing as to what is actually required. That said, the rules don't exclude deceased customers from SAR filings and we can only assume the silence on the topic implies applicability - at least, this is the conservative approach that will ensure compliance.
As your deceased customer was the one to conduct the transactions, I see no reason why you would not file a SAR listing your deceased customer as a suspect and including the fact that the customer is now deceased in the narrative. If it were me, I would attempt to file the SAR as late in the process as the rules permit so that I could include any applicable information regarding his death, with the goal being to not need to file a follow-up SAR if new information were to come in later in the process.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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