Goldreich-Oren still applies to NIZKs and SNARKs; the setup phase is the first verifier message. Even in SNARKs with transparent setup (eg, STARKs), the randomness used in the setup phase counts as the firstverifier message.
Ah, thanks for the correction. Do I have the soundness bit right? I guess it might apply even if the proof system is only computationally sound, since the simulator has to be efficient, right?