A non-volatile memory cell may include a semiconductor substrate; a source region in a portion of the substrate; a drain region within a portion of the substrate; a well region within a portion of the substrate. The memory cell may further include a first carrier tunneling layer over the substrate; a charge storage layer over the first carrier tunneling layer; a second carrier tunneling layer over the charge storage layer; and a conductive control gate over the second carrier tunneling layer. Specifically, the drain region is spaced apart from the source region, and the well region may surround at least a portion of the source and drain regions. In one example, the second carrier tunneling layer provides hole tunneling during an erasing operation and may include at least one dielectric layer.