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OLC concluded that because the CVRA defines “‘crime victim’ as a ‘person directly and proximately harmed by the commission of a Federal offense,’ . . . the definition of victim is thus tethered to the identification of a ‘Federal offense,’ an event that occurs with the filing of a complaint.” OLC further concluded that because the House Report stated that the CVRA codifies the “‘rights of crime victims in the Federal judicial system’” and a complaint “commences the ‘judicial process’ and places an offense within the ‘judicial system,’” the legislature must have intended for CVRA rights to commence upon the filing of a complaint. OLC also found that the language of the CVRA rights supported its interpretation. For example, the first right grants a victim protection from “the accused,” not a suspect. Additionally, the second, third, and fourth rights refer to “victim notification, and access to, public proceedings involving release, plea, sentencing or parole—none of which commence prior to the filing of a complaint.” B. 2005 Attorney General Guidelines for Victim and Witness Assistance In May 2005, the Department updated its Attorney General Guidelines for Victim and Witness Assistance (2005 Guidelines) to include the CVRA.” The 2005 Guidelines specifically cited the CVRA requirement that agencies “engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime victims are notified of, and accorded” their CVRA rights, which in 2005 encompassed the initial eight CVRA rights. The 2005 Guidelines provided detail regarding implementation of the Department’s CVRA duties and divided criminal cases into an “investigation stage,” a “prosecution stage,” and a “corrections stage.” The individuals responsible for notifying crime victims of their CVRA rights varied depending on the stage of the proceedings. During the “investigation stage” of cases in which the FBI was the investigating agency, the Special Agent in Charge was responsible for identifying the victims “[a]t the earliest opportunity after the detection of a crime” and notifying them of their rights under the CVRA and services available under the VRRA and other federal statutes. [D]uring the investigative stage, [the Department] mandates compliance with the Victims’ Rights and Restitution Act, 42 U.S.C § 10607, which requires federal officials to, among other things, identify victims, protect victims, arrange for victims to receive reasonable protection from suspected offenders, and provide The Availability of Crime Victims’ Rights Under the Crime Victims’ Rights Act of 2004 (Dec. 17, 2010) (“OLC Availability of Crime Victims’ Rights (2010)”’) and available at https://www.justice.gov/sites/default/files/ole/ opinions/2010/12/3 1/availability-crime-victims-rights.pdf. “That [2005] informal guidance did not foreclose the possibility that other definitions would also be reasonable.” OLC Availability of Crime Victims’ Rights (2010) at 1. 269 The 2005 Guidelines are set forth in relevant part in Chapter Three, Part Two, Section II of this Report. The Department promulgated the guidelines in response to a congressional directive in a predecessor statute to the CVRA, which instructed the Attorney General to develop and implement such guidelines. Victim and Witness Protection Act, Pub. L. No. 97-291, § 6, 96 Stat. 1248 (1982). The 2005 Guidelines were superseded in October 2011, as explained below. 193 DOJ-OGR- 00023231