Basically "no memory controller" means no circuit to do
wear leveling, but all other things as buffers, address demuxers, command decoder etc are there. It is simply NAND flash chip in plastic with pins collected on one side, so it is binary device, not analog device.
P.S. I was looking at a few patents describing technology to store analog values to NAND cells, but I don't think it's applicable to xD cards...