My bet here is that Simon's "death curse" looked like a major explosion followed by collapse of his fortress, and there was no checking for his body without moving hundreds of tons of rubble.
I think the White Council would do that if they had to. If Simon were taken alive by the Red Court and turned then the damage to the Council would be incalculable. They simply had to verify that he was dead, or find him if he was not.
But there's reason to believe that this didn't happen. In Summer Knight we find a description of the aftermath of Archangel.
"The Wardens said that they couldn't be sure, but it looked like someone let the killers in past the defenses. They didn't get away unscathed. There were the remains of half a dozen nobles of the Red Court. Many of their warriors. But they killed Simon and the rest."
The only way they could get a description like this would be if they could go in and see for themselves. WoJ confirms this, talking about the effects of a death curse: "See what happened to
all the vampires around Simon when they assaulted his compound immediately prior to the onstage events in Summer Knight." (emphasis added) It certainly sounds as though the effects of Simon's death curse could be seen by someone. It even suggests that his body was actually there. But if it was not then the White Council would still have to verify his death one way or another before they could sleep at night.