CVE-2025-54833 is a medium-severity vulnerability affecting OPEXUS FOIAXpress Public Access Link (PAL) version 11.1.0. The vulnerability stems from improper restriction of excessive authentication attempts (CWE-307) combined with an authentication bypass issue (CWE-602). Specifically, the affected version allows unauthenticated remote attackers to bypass both account lockout mechanisms and CAPTCHA protections designed to prevent brute force attacks. This means that an attacker can repeatedly attempt password guesses against user accounts without triggering lockouts or CAPTCHA challenges, significantly increasing the feasibility of password brute forcing. The vulnerability does not require any prior authentication or user interaction, and it is exploitable remotely over the network. The CVSS v3.1 base score is 5.3, reflecting a medium severity level, with the vector indicating network attack vector (AV:N), low attack complexity (AC:L), no privileges required (PR:N), no user interaction (UI:N), unchanged scope (S:U), limited confidentiality impact (C:L), and no impact on integrity or availability (I:N/A:N). 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 often contain sensitive or regulated information. The bypass of brute force protections could allow attackers to gain unauthorized access to user accounts, potentially exposing sensitive information or enabling further attacks within affected organizations.

For European organizations using OPEXUS FOIAXpress PAL v11.1.0, this vulnerability poses a significant risk to confidentiality. Since FOIAXpress PAL is used to manage FOIA requests, which may include personal data, government records, or other sensitive information, unauthorized access could lead to data breaches violating GDPR and other privacy regulations. The ability to brute force passwords without lockout or CAPTCHA increases the likelihood of successful account compromise, especially if users employ weak or reused passwords. While the vulnerability does not directly affect system integrity or availability, compromised accounts could be leveraged for privilege escalation or lateral movement within networks. This could be particularly impactful for public sector agencies, legal firms, or organizations handling sensitive public records across Europe. The lack of known exploits currently limits immediate risk, but the ease of exploitation and remote attack vector mean that threat actors could develop exploits rapidly. The medium severity rating suggests a moderate but non-negligible threat level, warranting prompt attention to prevent potential data exposure and compliance violations.

European organizations should implement the following specific mitigations: 1) Immediately audit FOIAXpress PAL deployments to identify instances running version 11.1.0 and prioritize upgrading to a patched version once available from OPEXUS. 2) In the interim, implement compensating controls such as network-level restrictions (e.g., IP whitelisting or rate limiting) on access to the PAL interface to reduce brute force attack surface. 3) Enforce strong password policies and encourage or mandate multi-factor authentication (MFA) for all user accounts accessing FOIAXpress PAL to mitigate the risk of password guessing. 4) Monitor authentication logs closely for abnormal login attempts or patterns indicative of brute force attacks, and integrate alerts into security information and event management (SIEM) systems. 5) Consider deploying web application firewalls (WAF) with custom rules to detect and block automated login attempts targeting the PAL interface. 6) Conduct user awareness training emphasizing the importance of unique, complex passwords and recognizing suspicious account activity. 7) Coordinate with OPEXUS support channels to obtain timely updates and patches, and verify the integrity of any updates before deployment. These measures go beyond generic advice by focusing on immediate risk reduction through network controls, enhanced monitoring, and user authentication hardening while awaiting official patches.