A method and corresponding structure for shielding a floating gate tunneling element. The method comprises disposing a floating gate over a gate oxide using standard CMOS processing in two active areas defined by first and second doped well regions formed in a substrate surrounded by field oxide, and forming a floating gate shield layer so as to enclose the floating gate. The floating gate includes a first floating gate portion over an active area in the first doped well region and a second floating gate portion over the active area in the second doped well region. The first floating gate portion is substantially smaller than the second floating gate portion so as to enable adequate voltage coupling for Fowler-Nordheim tunneling to occur between the first doped well region and the first floating gate portion. The direction of tunneling is determined by high voltage application to one of the doped well regions.