CVE-2025-54833 is a medium-severity vulnerability affecting OPEXUS FOIAXpress Public Access Link (PAL) version 11.1.0. The vulnerability arises from improper restriction of excessive authentication attempts (CWE-307) combined with an authentication bypass issue (CWE-602). Specifically, the product fails to enforce effective account lockout policies and CAPTCHA protections, allowing unauthenticated remote attackers to perform brute force password attacks more easily. This means that an attacker can repeatedly attempt to guess user credentials without being blocked or challenged by CAPTCHA mechanisms, increasing the likelihood of successful unauthorized access. The vulnerability does not require any user interaction or prior authentication, and the attack vector is network-based (remote). The CVSS v3.1 base score is 5.3, reflecting a medium severity rating, with the impact primarily on confidentiality (limited information disclosure risk) but no direct impact on integrity or availability. No known exploits are currently reported in the wild, and no patches have been linked yet. The vulnerability was published on July 31, 2025, and is assigned by CISA CG. The affected product, FOIAXpress PAL, is a public access portal used for managing Freedom of Information Act (FOIA) requests, which typically involves sensitive or regulated information access.

For European organizations, especially public sector entities and government agencies handling FOIA or similar public information requests, this vulnerability poses a significant risk to confidentiality. Successful brute force attacks could lead to unauthorized access to sensitive documents or personal data, potentially violating GDPR and other data protection regulations. The lack of effective lockout and CAPTCHA protections increases the risk of credential stuffing or password guessing attacks, which could compromise user accounts and expose confidential information. Although the vulnerability does not directly affect system integrity or availability, the breach of confidentiality could damage organizational reputation, lead to regulatory fines, and erode public trust. Additionally, attackers might leverage compromised accounts for further lateral movement or social engineering attacks within the organization. The medium severity rating suggests that while the threat is not critical, it warrants prompt attention due to the sensitive nature of the data involved and the ease of exploitation without authentication or user interaction.

Organizations using FOIAXpress PAL v11.1.0 should implement immediate compensating controls while awaiting an official patch from OPEXUS. These include: 1) Deploying Web Application Firewalls (WAFs) with rules to detect and block brute force patterns and excessive login attempts; 2) Implementing network-level rate limiting and IP blacklisting to restrict repeated authentication attempts from the same source; 3) Enforcing strong password policies and encouraging multi-factor authentication (MFA) where possible, even if not natively supported by the product; 4) Monitoring authentication logs for unusual patterns indicative of brute force attacks; 5) Restricting access to the PAL interface to trusted IP ranges or VPNs if feasible; 6) Educating users about strong password hygiene and potential phishing risks; 7) Coordinating with OPEXUS for timely updates and patches addressing this vulnerability; 8) Considering additional CAPTCHA or challenge-response mechanisms at the network or proxy level to supplement the deficient native protections. These measures go beyond generic advice by focusing on layered defenses and compensations tailored to the specific weakness in authentication controls.