This paper presents a realistic model that explicitly takes into account the electrostatic coupling between the nanocrystals of a disordered layer constituting the floating gate of a non-volatile memory. A statistical study of the neighborhood of a given nanocrystal is carried out, leading to the mean number of neighboring nanocrystals as a function of the radius of the central nanocrystal. We show that the empty neighborhood of every nanocrystal can be represented by an equivalent torus ring in the previous model of a single nanocrystal. Then the effects of charged nanocrystals are taken into account by an appropriate rigid shift of the energy levels of the central nanocrystal. The proposed model is validated by statistical comparisons with exact 3D computations, and the influence of the electrostatic coupling is analyzed and discussed.